Consent for Google Ads Personalization

Google Ads can effectively target advertisements to specific audiences using user data. However, since March 2024, Google has required businesses to obtain user consent before using their data to target customers in the EEA, UK, and Switzerland.

To comply with data privacy laws, your business must implement Google's Consent Mode v2. This framework allows you to collect data based on user preferences. This post will examine how consent works for Google Ads personalization, explore the steps you should take to comply, and highlight the negative consequences of non-compliance.

How Personalized Google Ads Work

Personalized Google Ads use data like browsing history, website interaction, and interests to show relevant ads to users. They help businesses reach the right audiences and improve ad performance.

Two personalization features of Google Ads that rely on user data are:

• Remarketing
• Targeted advertising

Remarketing means re-engaging people who have already visited your site. It does this by tailoring ads on Google search and other sites that display Google Ads (display partners). People who have visited your website before are more likely to turn into conversions than first-time visitors.

Targeted advertising lets Google display your ads to people most likely to click through and make purchases. Google builds up a profile of individual users' interests based on:

• Websites they visit
• Ad interactions
• App activity
• Location information
• Interests shared in their Google accounts

Personalized ads are popular with customers. A study by IAB Research found that 90% of customers prefer personalized ads and are 87% more likely to click on ads for products they're interested in buying. The key to reaping these benefits is ensuring you obtain user consent lawfully before sharing data with Google.

What Consent Means in Google Ads

In terms of personalizing Google Ads, consent means that users of your website or app agree you can collect and use their data for advertising purposes.

Since March 2024, Google has required all Google Ads users that target customers in the EEA, UK, or Switzerland to get users' consent before collecting their data and using it for targeted advertising. The EEA includes all the countries of the EU, plus Norway, Iceland, and Liechtenstein.

As the snippet from Google Ads Help shows below, a feature of Google Ads is the ability to target your ads to specific geographic locations. If you are targeting customers in European countries, you will need to ensure your consent settings are up to date:

How consent ensures legal compliance

Google has an obligation to comply with data protection laws, and it helps Google Ads users do the same. The laws that influence Google Consent Mode v2 include:

• General Data Protection Regulations (GDPR): EU data privacy laws that regulate how the personal data of people living in the EU is used. These laws apply to businesses in all parts of the world that target people living in the EU.
• UK GDPR: Data privacy laws the UK adopted after it left the European Union.
• ePrivacy Directive: Also known as the EU Cookie Law, this directive requires businesses to obtain user consent for activities such as tracking, profiling, and data collection. (Cookies are small pieces of data that identify you and remember your preferences.)

Google's EU User Consent Policy (EU UCP) has been in place since 2015. However, in a January 2024 announcement (extract below), Google stated it was stepping up enforcement of this policy for audience and measurement solutions. The company did this by:

• Requiring advertisers to send Google "verifiable consent signals"
• Making upgrades to its consent mode, known as Consent Mode v2

Let's explore how Consent Mode v2 works and how best to configure it for your business.

Understanding Google's Consent Mode V2

Google's Consent Mode v2 is a framework that establishes how your website communicates user consent to Google Ads and Google Analytics. Google collects data using Google tags - a snippet of code embedded in each page of your website that shares data about how users interact with your site after clicking an ad.

Consent Mode v2 helps you continue gathering data to measure conversions and other website insights while complying with data privacy laws.

Google Ads Help explains below how Google tags and consent mode work together:

When users land on your website and Consent Mode v2 is enabled, it can do three things:

• Communicate consent decisions to Google: This tells Google whether the user has given full or modified consent or has refused consent.
• Adjust data collection: If the user does not consent, it stops Google from collecting personally identifiable data.
• Build trust: Being transparent about how your website uses visitors’ data builds user confidence in your business.

As Google's About Consent Mode site highlights below, Consent Mode v2 does not provide a banner or widget for collecting user consent. Instead, it gathers data from your consent banner, which is a popup or banner on your website or app that asks the user for consent:

Obtaining user consent

When visitors from the EEA, Switzerland, or the UK access your website, you must make it clear that they can consent to or refuse to have their data collected.

In these countries, accessing your site does not mean they consent to you collecting their data (a system known as browsewrap).

Instead, you must use a clickwrap system - a consent banner or popup that requires customers to take action. The action could be clicking "I accept" or something similar, showing they consent to their data being collected and used.

The consent banner example below from Lakeland highlights that a clear consent banner contains the following:

• How the business uses personal data
• How users provide consent
• How to modify consent preferences

Sites using Google Ads share this information with Google, which can then use the data for enhanced data modeling to give you actionable insights into your website and marketing campaigns. This data can also be used for remarketing and targeted advertising.

Consent Mode v2 levels

There are two levels of consent mode - basic and advanced.

Basic consent mode

In basic consent mode, Google tags do not load until the user has given consent. This means no data will be passed from your website to Google until the user agrees. If the user consents, Google tags load, the consent status is shared, and Google can track their behavior and collect data.

If the user does not consent, Google does not receive any data, and even the consent mode status is not shared. In this mode, Google Analytics cannot perform behavioral modeling, leaving gaps in your data.

This is far from ideal for your business. Rather than using real data, you rely on Google's algorithm to guess how some users access your site and ads. Thankfully, advanced consent mode solves some of these issues.

Advanced consent mode

When you use advanced mode, Google tags load on your website or app as soon as a user opens it. The default mode is denied consent, but you can adjust this.

Here's the crucial difference: Even when consent is denied, advanced consent mode allows minimal data collection to monitor user interaction using cookieless pings. These pings are signals from nonconsenting users containing non-personal information.

Google Ads Help highlights the information pings can include:

Of course, full consent is preferable, but this data can still give Google some insights into non-consenting user activity. In advanced mode, you can also use behavioral modeling in Google Analytics to help you gain insights to drive website optimization.

Here's how Google Ads Help describes how conversion modeling works when users withhold consent:

Modeled conversions are directly integrated into your Google Ads campaign reports, so you still receive actionable insights despite not having access to user data. The following example, also from Google Ads Help, shows how you can compare conversion rates based on whether consent mode was used or not:

As seen below, Google Analytics Help highlights several best practices that advanced consent mode makes possible:

Each business needs to determine whether basic or advanced consent mode is right for it. However, there is a strong case that advanced mode provides more helpful, actionable insights that could help you target your marketing campaigns and website upgrades more effectively.

Once you have enabled consent mode, the user's settings will be preserved across all website pages. So, after making their initial choice, the user can enjoy a seamless experience.

Complying with Customer Match requirements

Google Match is a feature of Google Ads that assists with remarketing - re-engaging your customers through targeted advertising across the Google network, including YouTube, Google Search, Gmail, and display partners.

Customer Match uses online and offline personal data about your users. As seen below in Google Ads Help, you must work with your Customer Match partner to ensure compliance with Google's EU user consent policy by sending the right consent signals to Google.

Implementing Consent Mode V2

There are a few ways of implementing Google Consent Mode v2 on your website.

Manual implementation

If you manage your own consent banner, manual implementation is technically possible but complex. You need to update your website's code, adding consent mode logic to every Google tag. Additionally, you need to write code that checks the consent status and modifies tag behavior. It must also cover all consent scenarios and then check it works.

It's easy for errors to creep in with this option, so it is not recommended for most users.

Google Tag Manager (GTM)

GTM simplifies the process with a user-friendly interface that lets you manage and deploy tags, define consent status, and easily add consent mode parameters. With GTM, there is no need to modify code.

As seen below in the excerpt from Google Tag Manager Help, you can tailor these parameters to allow you to manage consent from EEA users. These parameters apply to Google Analytics, Google Ads, and Campaign Manager 360:

Consent Management Platform (CMP)

Google-certified CMPs are integrated with Google Tag Manager and Consent Mode v2. This makes it easier to implement consent settings on your website and continue lawfully gathering data and gaining crucial insights.

Essential Policies for Obtaining Consent

Users need to know what they are consenting to before they can provide consent. As seen in the example below from The North Face, you need to give your customers access to your privacy and cookies policies so they can give informed consent:

Privacy Policy

A Privacy Policy is a legal requirement, meaning you cannot do business without it. It establishes how you collect, store, and handle your website and app users' personal data.

It is important to update your privacy policy to comply with Google's EU User Consent Policy. As noted in the excerpt from Google's AdSense Help below, the policy requires you to tell users certain things, including:

• Types of data collected
• How data is stored and used, including in personalized advertising
• Which third parties you share personal data with
• How users can modify consent settings
• How to withdraw consent
• How to access Google’s Business Data Responsibility page

Your Privacy Policy must use clear language and be easily found on your website. It must also include your business's contact details if the user requires more information or wishes to complain.

Cookies Policy

A Cookies Policy lists all the cookies on your website and explains how they are used.

Some businesses create a separate cookies policy, or it can be part of a privacy policy. The GDPR and ePrivacy Directive explicitly require businesses to have a cookies policy, so it is essential for businesses targeting EU customers.

The Consequences for Not Implementing Consent Mode V2

If you do not implement Consent Mode v2, the impact and the legal compliance (complying with all relevant data protection laws) could be affected. Some potential results include:

• Limited data tracking: Google may not be able to track conversions from many European countries, leading to inaccurate performance metrics. Audience-based targeting will be less effective.
• Non-compliance with privacy regulations: Not implementing Consent Mode v2 is not an offense in itself, but if it leads to mishandling user data, you could be fined for breaching data privacy laws.
• Ad performance decline: Without the data Google needs for accurate modeling, your ad campaigns will lack direction, leading to higher costs and fewer conversions.

The takeaway: Implementing Consent Mode v2 is the best way to ensure compliance with data protection laws and optimize your Google Ads campaigns for European customers.

Summary

To continue running effective Google Ads campaigns targeting European customers, establish processes for obtaining explicit consent. Enabling Consent Mode v2 can help your business comply with GDPR and other European laws, but you will need to create your own consent banner or work with Google Tag Manager or a CMP to facilitate this process.

Consider using Advanced Mode in Consent Mode v2 to benefit from limited data collection even when consent is refused. This will give you greater insights into your customers through conversion modeling. Finally, maintain a clear and up-to-date Privacy Policy and Cookies Policy so users understand their rights over their personal data and what you plan to do with it.