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Is Google Analytics 4 GDPR Compliant?

Cody Schneider•

Wondering if Google Analytics 4 is compliant with GDPR is a huge source of stress for marketers and business owners. The short answer is: GA4 is not GDPR compliant straight out of the box, but it gives you the tools to make it compliant with the right configuration. This article will walk you through exactly what changed with GA4, what the legal landscape looks like, and the specific steps you need to take to use it without courting massive fines.

The GA4 and GDPR Compliance Controversy Explained

To understand the current situation, it helps to know how we got here. The core of the problem has always been about one thing: transferring personal data from European Union (EU) citizens to servers located in the United States. GDPR is very strict about this, requiring that US companies provide an "adequate" level of data protection equivalent to the EU’s standards.

A Quick Look Back: Universal Analytics and Schrems II

For years, companies relied on legal frameworks like "Privacy Shield" to justify these data transfers. However, in July 2020, the Court of Justice of the European Union invalidated Privacy Shield in a landmark case known as "Schrems II." This ruling threw a major wrench into things. It determined that US surveillance laws did not adequately protect EU citizens' data once it was on US soil. This had huge implications for any service sending data to the US, but Google Analytics was front and center. The previous version, Universal Analytics (UA), was a major offender. A few key issues made UA a compliance nightmare:

  • IP Address Collection: By default, UA collected and stored full IP addresses, which are considered Personally Identifiable Information (PII) under GDPR. You could anonymize them, but it required a manual setup that many businesses overlooked.

  • Uncontrolled Data Transfers: All that data, including IP addresses, was sent directly to Google's servers in the US without the level of protection EU regulators demanded.

Following the Schrems II ruling, data protection authorities in countries like Austria, France, and Italy began ruling that the use of Universal Analytics was illegal, setting a scary precedent for businesses across the EU.

How Google Addressed GDPR Concerns with GA4

Google knew this was an existential threat to its analytics platform, so GA4 was built from the ground up with privacy controls in mind. The goal was to give users the features they need to align their data collection practices with regulations like GDPR and the California Consumer Privacy Act (CCPA).

Key Privacy-Forward Changes in GA4

Compared to its predecessor, GA4 introduces several significant changes designed to make compliance easier to achieve.

  • IP Anonymization is Default: This is the biggest change. In GA4, IP anonymization is automatic and cannot be turned off. When GA4 collects data from an EU-based user, it first proxies the data through EU-based servers before sending it to US servers for processing, removing the IP address in the process. This alone resolves one of the biggest complaints leveled against UA.

  • Shorter Data Retention Controls: GA4 forces you to choose how long you store user-level data. The options are limited to either 2 months or 14 months, which encourages businesses to adopt a 'data minimization' mindset - a core principle of GDPR.

  • Granular Data Deletion: The "right to be forgotten" is a cornerstone of GDPR. GA4 makes it much easier to honor data deletion requests from users. You can delete specific data points for an individual user without having to wipe entire datasets.

  • Granular Location and Device Data Settings: GA4 allows you to disable the collection of precise location and device data on a per-region basis. This means you can keep collecting this detailed data for users in, say, Canada, while disabling it for users in Germany.

  • Goodbye, Third-Party Cookies: GA4 moves away from its reliance on third-party cookies, signaling a shift toward a privacy-focused, event-based measurement model that is less intrusive.

The Elephant in the Room: The EU-U.S. Data Privacy Framework

In July 2023, a new legal framework called the EU-U.S. Data Privacy Framework (DPF) went into effect. It effectively replaced the old Privacy Shield and created a new legal basis for transferring data from the EU to the US. Google (along with thousands of other US companies) has certified its compliance with this framework. So, does this mean you're in the clear? Not exactly. While the DPF provides a much stronger legal footing, it hasn't stopped the discussion. Privacy advocates almost immediately filed legal challenges against it, much like they did with Privacy Shield. Regulators in some more stringent EU member states may still choose to scrutinize data transfers closely. The lesson here is that you shouldn't rely solely on a legal framework to protect you. The safest approach is to use the tools GA4 provides to handle data responsibly in the first place.

Your Checklist for Making GA4 GDPR Compliant

Just turning on GA4 isn’t enough. True compliance is an active process that requires configuration and careful management. Here is a practical, step-by-step checklist to help you set up GA4 in a way that aligns with GDPR principles.

1. Set Up A Compliant Cookie Consent Banner

This is non-negotiable. You can’t track any anonymous user data without the user's explicit consent. Your cookie banner must:

  • Use "Opt-In" by Default: Analytics cookies must be disabled until a user actively clicks "Accept." Pre-ticked boxes are not compliant.

  • Be Granular: Users should be able to accept some cookies (like analytics) while rejecting others (like advertising).

  • Provide an Easy "Reject All" Option: The option to reject consent must be as simple and prominent as the option to accept.

To support this, Google introduced Consent Mode v2. This allows GA4 to receive consent signals from your banner and adjust its data collection accordingly, even providing some modeled, anonymous data for users who decline cookies.

2. Configure Data Retention Settings Appropriately

By default, GA4 stores user-level data (like everything you find in the explore reports) for 2 months. You have the option to extend this to 14 months. For GDPR, shorter is always better. Unless you have a strong, documented business reason for keeping granular data for over a year, stick with the 2-month default. You can change this setting by going to Admin > Data Settings > Data Retention.

3. Disable Granular Location and Device Data Collection

While GA4 already anonymizes IPs, you can go a step further by disabling the collection of detailed city-level location and device model information for users in the European Economic Area (EEA). This is a simple toggle switch:

  1. Go to Admin > Data Settings > Data Collection.

  2. Find the section for "Granular location and device data collection."

  3. Click the gear icon and turn the toggle off for any or all European countries.

This shows proactive data minimization and is highly recommended.

4. Disable Google Signals

Google Signals collects data for ads personalization and cross-device tracking. Because it involves user profiles, it falls into a gray area under GDPR. Unless you are running complex remarketing campaigns and have obtained explicit consent for ads personalization, it is safer to disable it. You can do this under Admin > Data Settings > Data Collection.

5. Establish a Data Deletion Request Process

Sooner or later, a user will ask you to delete their data. You need a process to handle this. In GA4, you can do this by going to Admin > Data Display > Data Deletion Requests. While it requires some technical steps to identify the user's specific client_id or user_id, having this tool available is essential for honoring the "right to erasure."

6. Don't Collect PII

This is a big one. You should never, under any circumstances, intentionally send personally identifiable information like names, email addresses, or phone numbers to Google Analytics. This is against Google's terms of service and GDPR. Audit your URLs, page titles, and custom events to make sure you're not accidentally capturing PII.

7. Update Your Privacy Policy

Your privacy policy must be crystal clear. Explicitly state that you use Google Analytics 4, what kind of data you collect through it, why you collect it, and for how long. Be transparent about the steps you’ve taken, like IP anonymization and your data retention period. You should also explain how users can opt out or request their data be deleted.

8. Consider Server-Side Tagging (For Advanced Users)

For businesses with a high-risk profile or those that want a bulletproof solution, server-side tagging offers an extra layer of control. Instead of sending data from a user's browser directly to Google, you send it to a tagging server that you control, hosted in the EU. This server then forwards cleaned, anonymized data to Google. This keeps you in complete control and ensures no raw user data ever leaves the EU.

Final Thoughts

Google Analytics 4 is not inherently GDPR-compliant, nor is it inherently non-compliant. It’s a tool, and like any tool, its compliance depends on how you use it. By implementing a proper consent banner, configuring data retention and collection settings, and being transparent with your users, you can create a setup that aligns with the principles of GDPR and minimizes your risk.

Making sure your GA4 setup is compliant is the first hurdle, the next is turning that complex data into actual insights. Setting up custom reports and dashboards within the GA4 interface can be a huge time commitment. That's a big reason we built Graphed. We connect directly to your GA4 account (and all your other marketing platforms) and let you build live dashboards just by asking questions in plain English. No more wrestling with the Explore reports - just connect, ask for what you need, and get back to making better decisions.