Ensuring Comprehensive and GDPR-Compliant Measurement with Piano Analytics

Given the increasing compliance challenges for businesses, audience measurement has become a more critical issue. However, some solutions offer configurations approved by the CNIL, provided that certain rules are followed. Piano Analytics, with its hybrid measurement approach, is one such example. Matthieu Bons, Manager Analytics & Conversion at Converteo, explains how it works.

Key Takeaways:

• Regulatory developments have made online audience measurement complex, as cookie placement now requires explicit user consent.
• The hybrid measurement, notably developed by Piano Analytics, still allows for comprehensive tracking of traffic on a site or application by offering various collection and measurement methods.
• Once implemented, hybrid measurement can recover a significant volume of traffic. Additionally, exempted events and parameters—validated on a case-by-case basis with the legal department—can enrich the data with additional contextual elements.
• However, it is important to anticipate the impact of such a configuration on the solution and audience analysis, as it may affect exports, dashboards, or analyses.

Today, CNIL regulations are clear: placing a tracking cookie on a browser requires explicit user consent. If consent is refused, data collection is not allowed. The consequence? The volume of measured traffic decreases: in France, the average consent rate is 72.1%, leaving 28% of potential traffic uncollected. Fortunately, solutions are gradually emerging to mitigate the impact of this measure. Provided they adhere to several rules set by CNIL, these solutions allow data collection without user consent, enabling comprehensive tracking of traffic on a site or application.

Three Collection Modes: “Opt-in”, “Exempt”, and “Opt-out”

In this context, Piano Analytics offers a “hybrid measurement” that differentiates data collection based on the user’s consent type, with three modes: “opt-in”, “exempt”, and “opt-out”.

In “opt-in” mode, the user has consented to cookies for audience measurement: the collection is comprehensive. For example, data such as visitor identification (client ID, etc.) or CRM categorization (professional/individual, prospect/client, etc.) can be collected, which is not possible with other consent modes.

In “exempt” mode, the user has not consented to or has refused analytics cookies. Data collection is then partial, including only parameters deemed strictly necessary for business operations, devoid of identifying information. For instance, for an e-commerce site, transaction data is considered essential for driving growth. In this mode, only the native parameters of a standard hit and information related to the page name and click name are collected.

Finally, in “opt-out” mode, the user has rejected the exempted data collection. In this case, the company cannot collect any data or can only do so within the framework of visitor anonymization. No cookies are placed, and it should not be possible to reconcile two events belonging to the same session.

On a Case-by-Case Basis, Enrichment Possibilities in “Exempt” Mode

Note: In “exempt” mode, it is indeed possible to enrich partial collection with additional parameters, subject to approval by the legal department. For example, information about transactions can be sent using a random identifier, which does not allow this information to be cross-referenced with transactions in the back office.

The first two collection modes can be defined and modified by the user at two stages: on the consent banner, when the user clicks “I accept” or “continue without accepting,” and in the consent management center. These two levels are typically managed by CMPs.

In contrast, the “opt-out” mode is defined in the navigation, generally via a link in the privacy policy or in the second level of privacy settings. This ensures legal compliance: at any point during navigation, a user must have the option to stop tracker monitoring.

Two Ways to Implement Hybrid Measurement

To implement hybrid measurement on a site or application, there are two options, each with its own advantages and disadvantages.

The first option is to wait for the user to make their choice before starting to collect data with the corresponding consent mode. The second option is to apply the “exempt” mode by default, and then adjust the data collection once the user has made a choice by clicking on the consent banner.

Once implemented, hybrid measurement allows for the collection of a significant volume of traffic, although variations may occur depending on the industry. Additionally, exempted events and parameters—validated with the legal department on a case-by-case basis—can also enrich the data with additional contextual elements.

Points of Attention

However, it is crucial to anticipate the impacts of such a configuration on the solution and audience analysis. In particular, deploying hybrid measurement requires signing an amendment with Piano Analytics. This amendment includes three prerequisites: masking the visitor ID property, anonymizing the last octet of the IP address, and purging personal data beyond 25 months. These changes can impact exports, dashboards, or analyses, and thus need to be anticipated.

Several factors can affect your analyses and require special attention. Among the measures that may be impacted are sales analysis, marketing source analysis, and non-exempt properties, which are now based on overall traffic rather than solely opt-in traffic as before, as well as data comparisons with other non-exempt tools.

Comparison periods that do not use the same type of traffic (opt-in vs exempt + opt-in) can also be affected. For example, if you analyze the page views of a page and compare it to a period when hybrid measurement was not implemented, the growth rates may be overestimated.

In conclusion, implementing Piano Analytics’ hybrid measurement allows for the recovery of traffic completeness and potentially engagement and conversion events depending on your configuration. However, the biases and impacts of this project need to be anticipated based on the maturity level of the teams handling the data in the tool.

Converteo teams can assist you with your exemption project by evaluating the impacts on your organization and implementing the operational mode suited to your needs.