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The growing popularity of blockchain technology is transforming how we approach data privacy and consent management.

Blockchain consent management provides a secure and transparent solution that empowers users to control their personal data. By leveraging the properties of blockchain technology, it provides an accountable and efficient way to handle permissions to access personal data. 

This shift represents not just an upgrade in technology from previous consent management options, but a fundamental change in how we think about data privacy and control.

Blockchain consent management provides a way to handle user data permissions securely and transparently. It’s a digital system that gives users control over how their personal information is used online. It acts like a customizable, trackable permission slip, enabling individuals to decide exactly what data to share, with whom, and for what purpose.

Unlike traditional agreements that rely on more broad, potentially vague consent, this system offers more precision. 

Every consent action, like granting or withdrawing permission, is securely recorded on a blockchain ledger. A blockchain ledger is like a shared digital spreadsheet that exists simultaneously on many computers. 

Everyone has the same updated information, and no single person can change it without everyone else knowing.

This means that the records are tamper-proof and easy to track. Companies can only access data if the user explicitly allows it. This helps organizations meet the requirements of privacy regulations, like the General Data Protection Regulation (GDPR), while giving users greater control.

Furthermore, the blockchain’s distributed ledger supports transparency and accountability, while smart contracts — known as self-executing digital agreements — automatically enforce consent rules. These “if/then” rules trigger actions only when specific conditions are met.

For example, a smart contract could automatically block a marketing company from using your personal data if you withdraw consent, instantly removing their access rights. When you update your preferences, the contract immediately enforces your wishes, preventing unauthorized data usage without requiring manual intervention.

This system reduces human error and simplifies compliance by helping to ensure data access happens only when the user’s requirements are fulfilled.

Traditional consent management systems are like filing cabinets where a company stores user permissions. You, as a user, typically agree to terms by clicking “I accept,” and the company keeps track of your consent in its own database. These systems are straightforward but have limitations in both transparency and user control.

Blockchain consent management is more advanced. Imagine a shared, digital ledger where every consent decision is recorded in a way that everyone can see, and that can’t be easily changed except by the relevant party making the consent decisions. 

This gives individuals more visibility into how their data is being used, and prevents companies from secretly modifying or ignoring users’ permissions.

The key differences lie in control and transparency. Traditional consent systems rely on companies to manage and track user permissions. This does work, but can leave users with limited visibility into how their data is used. 

Blockchain consent gives the user more say in how their information is shared. Relevant parties — users, companies requesting the permissions, third parties needing access to the data for processing — can see exactly who has accessed the data, when, and for what purpose.

Security is another key difference. Traditional systems are centralized, meaning data is stored in one place and subject to one company’s security measures, which can make it more vulnerable to unauthorized access. 

In contrast, the blockchain distributes information across multiple secure networks. This reduces the risk of a single point of failure and makes it harder to compromise any user’s data.

Blockchain consent management has the power to reshape the way companies handle user permissions. It solves some of the issues found in traditional systems by combining secure technology with features that benefit both users and businesses.

Here’s why companies are adopting blockchain for consent management.

The blockchain distributes data across multiple nodes, which reduces the risks of breaches or system failures. Since consent records are stored permanently, they can’t be altered without detection. This helps keep data secure and builds trust.

Every consent action is recorded in the equivalent of a transparent ledger. This makes it easy for users and regulators to track compliance. Organizations can also use this record to demonstrate compliance with privacy laws like the GDPR. This transparency can foster trust and reduce disputes over data use.

Blockchain offers more user control and privacy

Blockchain enables users to control exactly what data they share, with whom, and for what purpose. This is foundational for Privacy-Led Marketing, which focuses on ethical and user-centered practices. For businesses, it means having access to more accurate, consent-driven data that improves the efficiency of marketing campaigns.

On blockchain, users can set detailed preferences, specifying which data points they share and who can access them. This level of control supports universal consent management by enabling users to manage permissions across multiple platforms. This helps businesses align their data use with user expectations and build stronger customer relationships.

Blockchain uses smart contracts for automation

Smart contracts automatically enforce consent rules based on user preferences. They restrict data access to agreed parameters, reducing compliance risks. This automation also makes consent-based marketing easier by streamlining permission management.

Blockchain enables businesses to verify user consent instantly. They can then use data according to the latest permissions, improving operational efficiency. As blockchain also supports Privacy-Led Marketing, companies can rely on verified first-party consent.

Infographic presenting how the blockchain consent management works

Blockchain consent management offers a secure, transparent way to control how your personal information is used. Instead of relying on vague agreements or hidden terms, blockchain consent records and enforces your choices, and makes them easy to track. Here’s how it works:

  1. When you grant permission for a company to use your data, your choices are securely recorded on the blockchain.
  2. This record acts like a digital ledger, shared across multiple computers. This makes it nearly impossible to alter that record without your knowledge.
  3. You can decide exactly what data to share and with whom, which offers more precision than simply clicking “I agree.”
  4. Smart contracts enforce your consent choices, maintaining compliance without manual oversight.
  5. Every time someone accesses your data, it’s logged in the consent management of the blockchain. It creates a transparent history you can check anytime.
  6. If you change your mind, you can easily update your permissions, and the system will automatically follow your new preferences.

This approach puts the user in control of their personal information while giving companies a straightforward way to prove they’re respecting their audience’s wishes.

Checklist presenting the best practices for how o implement blockchain consent management

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Using blockchain for consent management can improve data control and security, but getting it right requires careful planning. Here are some best practices to keep in mind.

Start by identifying your organization’s specific consent requirements. Understand what types of data you manage and how consent is collected, stored, and used. Align these needs with your operational goals to help ensure the blockchain solution fits your processes.

Choose the right blockchain platform

Pick a platform that suits your company’s needs. Public blockchains like Ethereum offer transparency, but may not be suitable for sensitive data. Private blockchains, such as Corda — a popular option in the financial sector — provide more control and customization. This can be useful for compliance-heavy industries.

Confirm that it integrates with existing systems

Verify that the blockchain solution works well with your current systems to avoid operational disruptions. In addition, check that databases and interfaces can support blockchain’s distributed structure.

Provide user-friendly interfaces

The success of blockchain consent management depends on its usability. The system and its layout should be easy for your audience to use. This means creating simple dashboards where users can manage their data permissions. Work with user experience experts to design intuitive tools that simplify complex blockchain processes.

Educate stakeholders

Blockchain can be complex. Offer training sessions, workshops, or guides to help stakeholders understand its benefits. Clear communication builds trust and encourages adoption across your organization.

Use enhanced privacy tools

Employ technologies like encryption and zero-knowledge proofs to protect sensitive data stored on the blockchain. This keeps data secure while maintaining the transparency of the system.

Test and plan for scalability

Before rolling out a blockchain system, test it thoroughly before launching. Identify potential issues, such as slow performance or security risks. Plan for future growth by designing a system that can handle more users and transactions over time.

Implement smart contracts

Use smart contracts to automate blockchain consent management processes. These contracts can define terms, track permissions, and revoke access when needed. Make sure that the code is secure and reliable before deployment.

Continuously monitor and improve

Regularly review how the system performs and gather user feedback. Based on new data privacy regulations, implement mechanisms for users to easily adjust their consents and opt out when necessary. Make updates as needed to improve functionality and address issues that arise over time.

As data privacy laws tighten worldwide, many companies are seeking simpler ways to stay compliant. Blockchain consent management offers a solution that enhances compliance without disrupting operations.

Different regulations have unique requirements. Here’s how blockchain can address the specific demands of global data privacy laws.

The GDPR in the European Union sets high standards for data privacy. It emphasizes user consent and control over personal data. Blockchain technology aligns with several GDPR principles, including data minimization, transparency, and accountability. 

Blockchain technology provides a secure and transparent way for organizations to keep records of consent transactions. Once recorded, these records cannot be changed, making them resistant to tampering. This helps organizations easily track and prove compliance with regulatory requirements.

However, the GDPR also presents challenges that blockchain technology does not address. The regulation’s “right to be forgotten” requirement conflicts with blockchain because its records cannot be easily changed or deleted. To solve this, many companies use hybrid solutions. This typically means keeping personal data outside the blockchain while storing only consent-related information on it. 

Data privacy laws across the US

The United States does not have a single federal privacy law equivalent to the GDPR. However, state-level regulations like the California Consumer Privacy Act (CCPA), now amended by the California Privacy Rights Act (CPRA), introduced requirements for user consent and data control. Blockchain-based consent management systems could offer a tamper-proof record of user permissions, enabling businesses to demonstrate compliance with the CCPA’s requirements for data collection, deletion, and opt-out requests.

PIPEDA and blockchain in Canada

The Personal Information Protection and Electronic Documents Act (PIPEDA) in Canada emphasizes the importance of user consent for data collection and processing. Blockchain can support PIPEDA’s principles of accountability and individual access by offering a decentralized and user-centric consent management system.

LGPD compliance and blockchain in Brazil

Brazil’s General Data Protection Law (LGPD) closely mirrors the GDPR in its approach to data privacy. It mandates that personal data processing must be based on consent or other legal grounds, and individuals have the right to access, correct, and delete their data.

Blockchain technology can support a company’s efforts to be LGPD-compliant by providing transparency and security in consent management. However, like with the GDPR, blockchain’s permanent nature makes it difficult to delete data upon request. To comply with the law, companies may need to use off-chain solutions.

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Data privacy regulations in Asia

Privacy regulations throughout Asia, such as Japan’s Act on the Protection of Personal Information (APPI) and China’s Personal Information Protection Law (PIPL), impose strict requirements on data handling and user consent. 

In Japan, organizations must obtain clear user consent before processing personal data, and blockchain can provide a transparent and auditable method to record such consent. 

In China, the PIPL mandates strict data localization requirements. This means that blockchain consent solutions must support compliance by storing consent data in approved locations while maintaining operational efficiency.

At this point, blockchain may appear to be a promising solution for consent management. However, despite its potential, several challenges must be addressed within the technology before it can become a practical option for businesses.

Wrapping up: Blockchain’s role in compliance

Blockchain consent management isn’t a cure-all for data privacy challenges. Still, it does offer a practical solution for improving transparency, security, and user control. By addressing some limitations in traditional systems, it helps businesses navigate privacy regulations while respecting user preferences.

Its implementation, however, requires careful planning and some technical know-how. But as technology and data privacy regulations evolve, blockchain may play a role in shaping better data practices.

Privacy compliance used to be simpler. Your team would perhaps update privacy notices yearly, run occasional audits, and call it a day.

Now, it’s a daily challenge for enterprise companies that need to manage user consent across dozens of tools and platforms while navigating global privacy laws. You could spend countless hours reviewing tools one by one, checking boxes manually, and customizing implementations. This approach isn’t just time-consuming: it’s prone to errors and impossible to scale. 

Manual processes that worked a few years ago simply can’t keep up with today’s privacy regulations.

But here’s the good news: automation is changing how we handle data and privacy compliance, making it simpler and more reliable than ever.

What is compliance automation?

Compliance automation means using technology to minimize manual, administrative work in compliance activities.

With dedicated software solutions, companies can automate compliance to streamline various compliance procedures relevant to their industry. 

Compliance automation tools track internal systems, processes, and controls to check for adherence to the granular policies of applicable regulations and standards without requiring ongoing involvement. 

For example, when a user updates their privacy preferences, these changes automatically apply across connected tools and platforms.

This reduces the need for manual workflows while providing real-time insights that help organizations stay on top of compliance. As a result, companies not only boost efficiency, but can also continuously uphold regulatory standards.

Manual versus automated compliance management

Traditional, more manual compliance relies heavily on spreadsheets, email chains, and individual tool reviews. This approach typically requires privacy teams to spend hours gathering evidence, conducting access reviews, and documenting their findings. And because it’s time-intensive, manual compliance often means playing catch-up rather than staying proactively compliant.

In contrast, automated compliance streamlines these tasks. Consent preferences sync across tools, access reviews run on schedule, and documentation updates in real-time as systems change. Automation not only reduces administrative burden but can also strengthen security.

In fact, companies using security AI and automation saved an average of USD 2.2 million in breach costs compared to those without automation. By shifting to an automated approach, privacy teams can focus on strategy rather than routine tasks, improving both compliance and risk management.

Why is compliance automation important?

Managing consent at scale and keeping up with changing privacy laws across different regions can feel overwhelming. For many companies, manual compliance is a constant struggle.

Plus, privacy regulations have evolved rapidly in recent years:

Each law comes with its own definitions, enforcement mechanisms, and compliance obligations. So, a manual approach means constantly researching updates, retraining staff, and making changes across multiple systems. It’s an ongoing, resource-heavy process.

Given the number of global privacy laws, it’s no surprise that 95 percent of businesses are working to build a culture of compliance. But with regulations shifting, budgets tightening, and security threats increasing, keeping up can feel like an endless game of catch-up. That’s why more companies are turning to compliance automation.

Compliance automation helps businesses stay ahead of regulatory changes, strengthen security, and build customer trust. Instead of reacting to new requirements as they come, companies can implement scalable solutions that evolve with the laws, reducing risk while making compliance more efficient.

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Benefits of compliance automation

Keeping up with privacy regulations is a constant challenge, especially when relying on manual processes. Compliance automation removes much of the repetitive, time-consuming work, helping teams stay accurate, efficient, and ahead of regulatory changes.

Here’s why more and more companies are choosing to automate their data privacy compliance.

Instead of playing catch-up, companies can take a proactive approach. They can save time, reduce risk, and stay compliant without the extra workload that comes with manual compliance.

How does compliance automation work?

Think of compliance automation as a central control system for your privacy operations. It connects to your marketing tools, analytics platforms, and other systems through Application Programming Interface (API) integrations.

So, when an event happens — such as a user updating their privacy preferences — the system automatically applies the necessary changes across your technology stack.

But automation goes beyond handling individual events. It keeps compliance running smoothly in the background while covering three key areas: management, monitoring, and testing.

Automated compliance management

Automated compliance management covers your privacy program’s day to day operation. It handles tasks like syncing consent preferences, maintaining documentation, and keeping privacy practices consistent across systems.

For example, when a user updates their consent preferences on your website, an automated system will:

  1. Record the change in a central database
  2. Push updates to connected marketing tools like analytics, customer relationship management (CRM), and advertising platforms
  3. Generate and store a record of the change for future audit purposes
  4. Apply the appropriate data handling rules based on the user’s new preferences

All of this happens without manual intervention, which means that consent choices are respected instantly across your entire technology ecosystem.

Automated compliance monitoring

Automated compliance monitoring acts as an early warning system. Rather than discovering problems during periodic manual reviews, the system continuously checks for potential issues and will alert you when something needs attention.

A good monitoring system will:

  1. Regularly scan your website and apps for unauthorized trackers or tags
  2. Check that privacy notices match your actual data collection practices
  3. Verify proper consent collection before data processing begins
  4. Alert teams to potential compliance gaps before they become significant issues

This continuous monitoring approach means you’re no longer working with outdated compliance information or discovering problems months after they appear.

Automated compliance testing

Automated compliance testing helps verify that your privacy practices work as intended. It can regularly check system configurations, test consent collection and management, and support proper data handling across your tools.

Automated testing might include:

  1. Simulating user interactions with consent mechanisms to verify proper function
  2. Checking data flows to ensure information only moves where permitted
  3. Verifying that privacy preferences persist across user sessions
  4. Confirming that data subject rights requests are properly processed

By automating these tests, organizations can maintain confidence in their privacy practices without spending time and resources on manual verification for every scenario.

How to get started with compliance automation

Infographic presenting the steps to follow to implement compliance automation

Here’s a quick run-through of how you can implement compliance automation.

1. Assess your current compliance needs

Begin by identifying your regulatory obligations. These will be based on your business activities, geographic scope, and industry. Determine which specific compliance areas cause the most friction in your operations.

2. Map your technology ecosystem

Document all the tools, platforms, and systems that process personal data. These may include marketing analytics, CRM systems, email platforms, advertising tools, and website technologies. Understanding your tech landscape will make for smoother integration.

3. Define your compliance automation goals

Identify the compliance tasks that will benefit most from automation. Prioritize areas that are time-consuming or prone to error, such as:

4. Select the right automation platform

Focus on finding an automation platform that integrates seamlessly with your existing technology stack. It should meet the unique needs of your industry and be scalable as your business grows.

Additionally, choose a platform that provides regular updates to stay aligned with evolving regulations.

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5. Implement automated regulatory compliance in phases

Start with thoroughly automating one compliance area before expanding. Many companies begin with consent management automation before moving to more complex areas, like documentation or testing.

6. Train your teams

Make sure your marketing, IT, and legal teams understand the new automated workflows and their responsibilities within the system.

7. Monitor and refine

Regularly assess the effectiveness of your automation solution and adjust as needed to improve efficiency and compliance outcomes.

Common challenges of compliance automation and how to overcome them

While compliance automation offers significant benefits, successful implementation comes with challenges. Here’s how to overcome some of the most common obstacles.

Integration complexities

One of the main challenges is connecting automated systems with existing tools and platforms. To do so, start with key integrations and expand gradually. 

Work with vendors that offer pre-built connections to common platforms, and prioritize automation for systems that handle sensitive data or present the highest compliance risks. 

Middleware solutions can also help bridge gaps between systems that don’t have native integration capabilities.

Team adoption

Getting teams to trust and effectively use automated solutions can be difficult. To ease the transition, provide clear training on new workflows and demonstrate how automation saves time and reduces errors. 

Involve key stakeholders early in the implementation process and document success stories where automation prevented compliance issues or improved efficiency. 

Simple guides explaining how automation changes daily processes for different teams can also be helpful.

Maintaining human oversight

Finding the right balance between the ease of automation and the necessity of human judgment is crucial. Automate routine tasks, but keep strategic decision-making in the hands of your team. 

Set clear criteria for when human review is necessary and establish escalation paths in case potential issues arise. 

Regularly review how automation is performing, and adjust human oversight as needed. 

Managing upfront costs

The initial investment in compliance automation can raise concerns. While it’s true that there is an upfront cost for software and implementation, the long-term savings quickly offset these expenses by reducing compliance overhead and avoiding costly fines. 

Companies may benefit from starting with smaller automation projects that demonstrate clear ROI. Alternatively, consider phased implementation approaches to spread costs over time.

Automated compliance across different industries

Compliance automation needs vary significantly across industries, with each sector facing unique regulatory requirements and operational challenges. Organizations need to understand industry-specific applications to implement the most effective compliance automation strategies.

Automated compliance in the finance industry

The finance and banking industries operate under some of the strictest regulations. Automation plays a crucial role in handling processes like Know Your Customer (KYC), anti-money laundering (AML) checks, and risk assessments.

For financial institutions, compliance automation can simplify tasks like:

This approach not only supports compliance but also streamlines operations, enhancing efficiency and the customer experience.

Regulatory compliance automation in the healthcare sector

Healthcare organizations in the US must balance Health Insurance Portability and Accountability Act (HIPAA) compliance, as well as following other regulations, while delivering top quality patient care. 

Automation helps manage access to patient data, maintains audit trails, and supports consent management.

In healthcare, compliance automation typically covers:

These automated processes enable healthcare organizations to prioritize patient care while safeguarding privacy and meeting regulatory standards.

Automated security compliance in ecommerce 

Ecommerce businesses face the challenge of managing privacy compliance across multiple regions. Automated systems help track local regulations, handle cookie consent, and manage data subject rights requests. These steps are especially important as privacy laws continue to evolve globally.

For ecommerce businesses, compliance automation often includes:

These automated solutions enable ecommerce businesses to scale internationally while maintaining consistent compliance with various privacy laws.

IT and security compliance automation

For IT teams, compliance automation is essential for managing security and risk.

Cybersecurity threats are on the rise, and compliance regulations demand strict controls over data access, storage, and usage. Without automation, maintaining compliance can be time-consuming and expensive. However, companies that do implement compliance technology have cited reduced compliance costs by an average of USD 1.45 million.

IT compliance automation also helps businesses stay ahead by enabling continuous security monitoring and aligning systems with industry standards like ISO 27001, NIST, and SOC 2. Common functions of automated compliance solutions include:

  1. Continuously assessing security posture against regulatory requirements
  2. Automatically documenting security controls for audit purposes
  3. Regularly scanning for unauthorized system changes or configurations
  4. Collecting evidence of security practice implementation
  5. Streamlining security incident response workflows

Patching is another critical compliance requirement that automation makes more manageable. Security patches must be applied promptly to prevent vulnerabilities, yet manual patching can be inconsistent and prone to delays. Automated patching keeps systems up to date, which reduces security risks and keeps organizations in compliance with regulatory requirements.

Access management also plays a key role in IT compliance automation. Many regulations require strict control over who can access sensitive data. Instead of relying on manual reviews, compliance automation enforces user access policies, automates regular access reviews, and ensures proper role-based controls, which minimizes the risk of unauthorized access.

By integrating compliance automation into security processes, IT teams can reduce costs, minimize regulatory risk, and maintain continuous compliance without the burden of manual upkeep.

How Usercentrics can help your compliance automation efforts

Manual compliance processes take too much time, increase the risk of errors, and are difficult to keep up with as regulations change. Compliance automation helps businesses stay on top of requirements without the constant manual effort.  

Usercentrics Consent Management Platform can help you simplify privacy compliance by automating key tasks like consent management across your websites and apps. We’ll help make it easier to follow privacy laws such as the GDPR and the CPRA. 

Usercentrics can help you:

  1. Automate consent collection with customizable, on-brand user interfaces that meet regulatory requirements across jurisdictions.
  2. Sync consent preferences automatically across your technology stack, helping you achieve consistent privacy standards throughout your digital ecosystem.
  3. Provide comprehensive and secure compliance records to maintain complete audit trails of consent activities and privacy preference changes.
  4. Monitor compliance status through real-time dashboards that highlight potential issues before they become problems.

Instead of tracking regulations manually, businesses can rely on our compliance automation to collect data and user permissions in a privacy-compliant way.

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A comprehensive survey of 600 business leaders across major European markets reveals that privacy management has evolved from a compliance requirement to a strategic business priority, with nearly three-quarters of privacy decisions now being made at the executive level.

The study — which gathered insights from equal numbers of respondents in the UK, Germany, Spain, and Italy — reveals that privacy management has become a C-suite concern, with 73 percent of respondents being senior executives. Senior-level involvement in the planning of consent management within companies marks a significant shift in how organizations approach data privacy in the post-GDPR era.

The research also shows a notable divide in privacy management approaches. Fifty-six percent of organizations handle privacy matters in-house, and 44 percent have adopted a hybrid approach that combines internal and external expertise. This split becomes more pronounced when analyzed by company size. Larger organizations are more likely to employ hybrid solutions due to the increasing complexity of privacy requirements.

Key findings include:

Industry distribution in the survey suggests that sectors with the most digital customer interactions — software technology, professional services, and retail — are leading the way in privacy adaptation. This mirrors how digital transformation spreads across industries, with some sectors blazing trails that others would later follow.

Strategic move

This survey provides a window into the future. The behavior of European businesses is particularly relevant because it reveals how markets mature and adapt when privacy regulations become a long-standing reality rather than a new development. The UK, Germany, Spain, and Italy are now considered mature markets when it comes to data privacy.

These markets represent the most developed regulatory environments for privacy in the world. The EU has been at the forefront of privacy regulation since the Data Protection Directive of 1995, which then evolved into the General Data Protection Regulation in 2018. This means European businesses of all sizes have had more time to move beyond initial compliance scrambles and develop more sophisticated approaches. Their behavior shows us the “steady state” of privacy management, rather than the reaction to new rules.

What this survey reveals about privacy strategy amongst European businesses contradicts the common narrative that regulations simply burden organizations. The European experience can serve as a predictive model for other regions.

Many markets, like California with the CCPA/CPRA, Brazil with the LGPD, and other jurisdictions currently implementing privacy regulations are — significantly or at least in part — following the European regulatory path. By understanding how European organizations have evolved, businesses in these emerging privacy markets can anticipate their own trajectories and potentially skip painful stages of adaptation.

This approach to privacy has become increasingly influential globally. Major technology platforms have often found it more efficient to adopt European standards internationally rather than maintain different privacy standards for different regions.

This “Brussels Effect” — the process of European Union regulations spreading well beyond its borders — means that European privacy practices often become de facto global standards. European business behaviors are often therefore leading indicators for global trends.

From a competitive standpoint, privacy-compatible business models, with solutions to balance personalization with privacy, data utility with data protection, and marketing effectiveness with user consent, provide valuable blueprints for organizations just beginning this journey.

The trend of elevating privacy concerns to executive levels in European businesses demonstrates that privacy adaptation requires significant organizational change. This insight can help organizations in other regions prepare, not just with technical solutions, but with appropriate governance structures and executive engagement.

The European business response to privacy regulation that this survey reveals isn’t just a regional curiosity. It’s a preview of the future for organizations worldwide. It offers both cautionary lessons and strategic inspirations for navigating an increasingly privacy-conscious business environment.

Company size

The management approaches revealed in the survey, i.e. the split between in-house (56 percent) and hybrid management (44 percent), also suggest that we’re moving toward a future where privacy management will become a core business function, in a way similar to how digital marketing evolved.

In that case, organizations initially outsourced digital marketing entirely, then gradually built internal capabilities while maintaining external partnerships for specialized needs. The preference for in-house privacy management among small businesses reflects both their resource constraints and need for direct control. Unlike large enterprises, smaller organizations will often manage data privacy with minimal outsourcing.

The company size distribution in the survey helps us understand how this future might unfold differently across organizations. Small businesses, which made up 47 percent of respondents, will likely drive innovation in simplified privacy solutions. Larger organizations, with more resources but also more complex needs, will probably lead in developing comprehensive privacy frameworks that smaller organizations can later adapt.

The mid-sized companies (those with 51-250 employees) show an interesting pattern. They’re more likely to use a hybrid approach of both in-house and agency support. This makes sense when we consider: they’re large enough to have complex privacy needs but might not have the resources to build comprehensive in-house privacy teams.

They’re in what we might call the “complexity sweet spot.” Large enough to need sophisticated privacy management but not so large that they can easily build it all internally.

Large enterprises (251+ employees) show yet another pattern. With their greater resources, they’re more likely to have dedicated privacy teams and sophisticated internal processes.

However, they also face more complex challenges due to their scale, with more data, more customer interactions, and more jurisdictions to consider. Therefore, many still opt for hybrid approaches, combining internal expertise with external specialized support.

This analysis helps us understand why one size fits all approaches to privacy compliance often fall short. A small business owner personally managing their website’s cookie banner has very different needs and capabilities compared to a large enterprise with multiple websites across several jurisdictions. Still, both need to meet similar compliance standards.

These patterns suggest several key trends for the future.

  1. Privacy as a brand differentiator: The high level of executive involvement suggests privacy will become a key brand value proposition, similar to how sustainability has become a core business message.
  2. Technological integration: The challenges reported in implementation point to a future where privacy controls are deeply embedded in marketing technology, rather than being add-on features.
  3. Skill evolution: The identified need for better understanding and training suggests that new roles and skills will emerge, and may lead to positions like Privacy Marketing Specialist or Consent Optimization Manager.
  4. Market segmentation: The varying approaches based on company size suggest a future market of privacy solutions segmented by organization scale and complexity, rather than one size fits all solutions.
  5. Cultural shift: The shift toward explicit consent and user control indicates a broader shift in how organizations view their relationship with customer data.

To understand where the industry is heading, it’s helpful to think about how other branches of digital marketing evolved. For instance, email marketing began with few restrictions, went through a period of increasing regulation, and eventually emerged with new best practices that balanced marketing effectiveness with user rights. Privacy-Led Marketing appears to be on a similar journey, with even broader implications.

About the research

The research was conducted by Sapio on behalf of Usercentrics in December 2024 and is based on interviews with 600 respondents (of those, 150 were in the UK/Germany/Spain/Italy) who have decision-making power over their company’s website and consent banners, including legal and compliance roles, web developers/owners and senior marketing decision-makers from all company sizes, as well as owners, C-level executives, and directors from small businesses.

Watch our on-demand session to learn how to properly manage cookies and avoid legal risks.

This webinar, featuring Magdalena Aleksova (Usercentrics) and Adrian Nowakowski (Up Blue), provides practical insights into cookie compliance, legal risks, and best practices for managing cookies on your website.

What You’ll Learn:

Who Should Watch?

In addition to being convenient and efficient, single sign-on is meant to be a more secure way to handle user logins. Instead of having to set up and record or remember separate usernames and passwords for every site, individuals can login with account credentials they already have. Large tech platforms accounts are popular options, like Google or Facebook.

But that added security and convenience can result in a privacy violation if requirements of data privacy laws like the European Union’s General Data Protection Regulation (GDPR). Where is the data that’s collected stored? And who may have access to it?

This type of issue is what happened when visitors to a website managed by the European Commission were able to login using social platform credentials, resulting in an infringement to EU citizens’ privacy rights.

We look at what happened and how, as well as how the Commission was penalized and what companies can learn to employ single sign-on compliantly.

Conference on the Future of Europe website login and the complaint

The Conference on the Future of Europe ran in 2021 and 2022, and visitors to the website could register for the various related events there. The European Commission (the Commission) managed the conference website. 

One of the login options for visitors interested in registering for conference events was single sign-on using social platform login credentials. Specifically, there was a “Sign in with Facebook” link on the login web page.

However, as Meta Platforms, Facebook’s parent company, is located in the United States, if an EU resident used this login method, it created the conditions for that user’s personal data to potentially be transferred to the United States without the individual’s knowledge or consent. 

Who was affected by the GDPR violation?

An individual residing in Germany logged in to the conference website and registered for the “GoGreen” event using his Facebook account credentials. According to the individual, in doing so, his personal data was collected and transferred to the US, including IP address plus browser and device information. 

Amazon Web Services was the operator of the Amazon CloudFront content delivery network in use by the conference website, which is how his personal data was transferred. Amazon is also based in the United States. 

The individual who made the complaint maintained that the data transfers created a risk of his data being accessed by US security and intelligence services. An additional claim was that neither the Commission nor conference organizers indicated that appropriate measures were in place to prevent or justify those data transfers if visitors used that sign-in method.

How did the European Commission violate the GDPR?

The Court of Justice of the European Union (CJEU) found that the “Sign in with Facebook” link on the conference website created conditions for transferring the complainant’s personal data to Facebook, which, as noted, is based in the US. As the European Commission managed the conference website, they were responsible for the data transfer and contravened their own rules.

At the time the transfer occurred (the conference ran in 2021 and 2022), the US was not considered adequate for ensuring data protections for the personal data of EU residents. The EU-U.S. Privacy Shield framework had been struck down in 2020 and the EU-U.S. Data Privacy Framework, which introduced a new adequacy agreement between the two regions, was not enacted until 2023.

Additionally, the Commission was found not to have demonstrated nor claimed that an appropriate safeguard for personal data transfers was in place for personal data obtained and transferred via the login using Facebook account credentials, i.e. a standard contractual clause or data protection clause. Facebook’s platform entirely governed the terms and conditions of displaying — and as a result, logging in with — the “Sign in with Facebook” link.

The CJEU found that the Commission did not comply with the requirements of EU law for data transfers to a third country by “an EU institution, body, office or agency” (Chapter 5 GDPR.)

How was the complaint resolved?

The complainant was awarded EUR 400 by the CJEU, to be paid by the European Commission, as compensation for non-material damage experienced due to the data transfers.

The complainant also sought several other methods of redress, including:

The CJEU dismissed all three. The Court found that in one connection the data was transferred to a server in Germany, rather than to the United States, as Amazon Web Services is required to ensure that data remains in Europe in transit and at rest. 

In another connection, the Court found that the complainant was responsible for the redirection of the data to US-based services via the Amazon CloudFront routing mechanism. A technical adjustment made the complainant appear to be located in the US at that time. Using a VPN can cause this result.

How can companies operating in digital spaces protect their operations?

Single sign-on options using popular tech platforms are convenient. But companies that knowingly or that may process personal data from EU residents need to be aware of how the login process works, what personal data is collected, where it may be transferred to and stored, and who may have access to it. Users whose personal data may be processed need to be informed as well and enabled to exercise their rights under relevant laws. 

Facebook and Google are two such popular platforms where their account credentials are used for single sign-on, and they are both US-based companies, though they do have EU-based servers and data centers, necessitated by certain legal requirements.

If providing such login options is necessary on your website, ensure that the required agreements and/or contractual clauses to ensure adequate data protection are in place and that users are adequately informed and their privacy rights — including consent or opt-out — are maintained. 

This also goes for other third-party services that process users’ personal data, which many companies use on their websites for advertising, analytics, ecommerce fulfillment, and other functions. Under the GDPR and other data privacy laws, controllers are responsible for the privacy compliance and data security of third-party processors working for them.

Obtain informed and explicit consent from website visitors and others whose personal data is collected and processed for various purposes, so that they know about the data processing and third parties that may have access to their data, and can exercise their rights and consent choices. 

A consent management platform would have enabled the Commission to notify users about personal data collection and transfer and obtain their consent. Or enable them to use another login option if they declined.

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Usercentrics does not provide legal advice, and information is provided for educational purposes only. We always recommend engaging qualified legal counsel or privacy specialists regarding data privacy and protection issues and operations.

The General Data Protection Regulation (GDPR) sets strict standards for how organizations must handle personal data collected from individuals in the European Union (EU) and European Economic Area (EEA). This comprehensive data protection regulation applies to all organizations that collect or process this data — regardless of where the organization is located — if they offer goods or services to EU/EEA residents or monitor their behavior.

Among its many requirements, the GDPR places specific legal obligations on how organizations may handle special categories of personal data or sensitive personal data. These data categories receive additional protections due to their potential impact on an individual’s rights and freedoms if they are misused.

In this article, we’ll look at what constitutes sensitive personal data under the GDPR, what additional protections it receives, and the steps organizations can take to achieve compliance with the GDPR’s requirements.

What is sensitive personal data under the GDPR?

Sensitive personal data includes specific categories of data that require heightened protection under the GDPR, because their misuse could significantly impact an individual’s fundamental rights and freedoms.

Under Art. 9 GDPR, sensitive personal data is:

Recital 51 GDPR elaborates that the processing of photographs is not automatically considered processing of sensitive personal data. Photographs fall under the definition of biometric data only when processed through specific technical means that allow the unique identification or authentication of a natural person.

By default, the processing of sensitive personal data is prohibited under the GDPR. Organizations must meet specific conditions to lawfully handle such information.

This higher standard of protection reflects the potential risks associated with the misuse of sensitive personal data, which could lead to discrimination, privacy violations, or other forms of harm.

What is the difference between personal data and sensitive personal data?

Under the GDPR, personal data includes any information that can identify a natural person — known as a data subject under the regulation — either directly or indirectly. This may include details such as an individual’s name, phone number, email address, physical address, ID numbers, and even IP address and information collected via browser cookies.

While all personal data requires protection, sensitive personal data faces stricter processing requirements and heightened protection standards. Organizations must meet specific conditions before they can collect or process it.

The distinction lies in both the nature of the data and its potential impact if misused. Regular personal data helps identify an individual, while sensitive personal data can reveal intimate details about a person’s life, beliefs, health, financial status, or characteristics that could lead to discrimination or other serious consequences if compromised.

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Conditions required for processing GDPR sensitive personal data

Under the GDPR, processing sensitive personal data is prohibited by default. However, Art. 9 GDPR outlines specific conditions under which processing is allowed.

Explicit consent given by the data subject, with the right to withdraw Required for legal obligations in employment or social protection Necessary to protect life when consent cannot be given Processed by nonprofits for members, without external disclosure Made publicly available by the data subject Required for legal proceedings or judicial actions Necessary for substantial public interest under the law Needed for medical care, diagnosis, or health system management Used for disease control or medical safety, with confidentiality safeguards Required for archiving, scientific research, or statistical purposes

The GDPR authorizes EU member states to implement additional rules or restrictions for processing genetic, biometric, or healthcare data. They may establish stricter standards or safeguards beyond the regulation’s requirements.

Art. 4 GDPR defines consent as “any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.”

Although the GDPR does not separately define explicit consent, it does require a clear and unambiguous action from users to express their acceptance of data processing. In other words, users must take deliberate steps to consent to their personal data being collected. Pre-ticked boxes, inactivity, or implied consent through continued use of a service do not meet GDPR requirements for explicit consent.

Common examples of explicit consent mechanisms include:

Additional compliance requirements for processing sensitive personal data under the GDPR

Organizations processing personal data under the GDPR must follow several core obligations. These include maintaining records of processing activities, providing transparent information on data practices, and adhering to principles such as data minimization and purpose limitation. However, processing sensitive personal data requires additional safeguards due to the potential risks involved.

Data Protection Officer (DPO)

Organizations with core activities that involve large-scale processing of sensitive personal data must appoint a Data Protection Officer (DPO) under Art. 37 GDPR. The DPO may be an employee of the organization or an outside consultant.

Among other responsibilities, the DPO monitors GDPR compliance, advises on data protection obligations, and acts as a point of contact for regulatory authorities.

Data Protection Impact Assessment (DPIA)

Art. 35 GDPR requires a Data Protection Impact Assessment (DPIA) for processing operations that are likely to result in high risks to individuals’ rights and freedoms. A DPIA is particularly important when processing sensitive data on a large scale. This assessment helps organizations identify and minimize data protection risks before beginning processing activities.

Restrictions on automated processing and profiling

Art. 22 GDPR prohibits automated decision-making, including profiling, based on sensitive personal data unless one of the following applies:

If automated processing of sensitive personal data is permitted under these conditions, organizations must implement safeguards to protect individuals’ rights and freedoms.

Penalties for noncompliance with the GDPR

GDPR penalties are substantial. There are two tiers of fines based on the severity of the infringement or if it’s a repeat offense.

For severe infringements, organizations face fines up to:

Less severe violations can result in fines up to:

While violations involving sensitive personal data are often categorized as severe, supervisory authorities will consider the specific circumstances of each case when determining penalties.

Practical steps for organizations to protect GDPR sensitive personal data

Organizations handling sensitive personal data must take proactive measures to meet GDPR requirements and protect data subjects’ rights.

Conduct data mapping

Organizations should identify and document all instances in which sensitive personal data is collected, processed, stored, or shared. This includes tracking data flows across internal systems and third-party services. A thorough data inventory helps organizations assess risks, implement appropriate safeguards, and respond to data subject requests efficiently.

Develop internal policies

Establish clear internal policies and procedures to guide employees through the proper handling of sensitive personal data. These policies should cover, among other things, data access controls, storage limitations, security protocols, and breach response procedures, as well as specific procedures for data collection, storage, processing, and deletion. Organizations should conduct regular training programs to help employees understand their responsibilities and recognize potential compliance risks.

The GDPR requires businesses to obtain explicit consent before processing sensitive personal data. Consent management platforms (CMPs) like Usercentrics CMP provide transparent mechanisms for users to grant or withdraw explicit consent, which enables organizations to be transparent about their data practices and maintain detailed records of consent choices.

Manage third-party relationships

Many businesses rely on third-party vendors to process sensitive personal data, so it’s essential that these partners meet GDPR standards. Organizations should implement comprehensive data processing agreements (DPAs) that define each party’s responsibilities, outline security requirements, and specify how data will be handled, stored, and deleted. Businesses should also conduct due diligence on vendors to confirm their compliance practices before engaging in data processing activities. 

Perform regular audits

Conducting periodic reviews of data processing activities helps businesses identify compliance gaps and address risks before they become violations. Review consent management practices, security controls, and third-party agreements on a regular basis to maintain GDPR compliance and respond effectively to regulatory scrutiny.

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Checklist for GDPR sensitive personal data handling compliance

Below is a non-exhaustive checklist to help your organization handle sensitive personal data in compliance with the GDPR. This checklist includes general data processing requirements as well as additional safeguards specific to sensitive personal data. 

Obtain explicit consent before processing sensitive data Make consent withdrawal simple and accessible Stop processing data if consent is withdrawn Implement strong security measures to protect sensitive data Document all processing activities with their purpose, legal basis, and retention periods Create clear privacy policies about data usage and users’ rights Review and update data protection policies often Train employees on GDPR requirements and data handling rules Set up data breach detection and reporting systems Conduct Data Protection Impact Assessments (DPIAs) for high-risk data processing activities Assess whether you need a Data Protection Officer Review third-party processor compliance regularly
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For advice specific to your organization, we strongly recommend consulting a qualified legal professional or data privacy expert.

Usercentrics does not provide legal advice, and information is provided for educational purposes only. We always recommend engaging qualified legal counsel or privacy specialists regarding data privacy and protection issues and operations.

Google Analytics is a powerful tool for understanding website performance, user behavior, and traffic patterns. However, its compliance with the General Data Protection Regulation (GDPR) has been a subject of concern and controversy, particularly in the European Union (EU). The data protection authorities of several European Union (EU) countries have weighed in on privacy compliance issues with Google Analytics, with similar complaints that focus on its insufficient protections and data transfer practices.

In this article, we’ll examine the timeline of EU-US data transfers and the law, the relationship between Google Analytics and data privacy, and whether Google’s popular service is — or can be — GDPR-compliant.

Google Analytics and data transfers between the EU and US

One of the key compliance issues with Google Analytics is its storage of user data, including EU residents’ personal information, on US-based servers. Because Google is a US-owned company, the data it collects is subject to US surveillance laws, potentially creating conflicts with EU privacy rights.

The EU-US Privacy Shield was invalidated in 2020 with the Schrems II ruling, and there was no framework or Standard Contractual Clauses (SCC) in place for EU to US data transfers until September 2021 when new SCCs were implemented. These were viewed as a somewhat adequate safeguard if there were additional measures like encryption or anonymization in place to make data inaccessible by US authorities.

A wave of rulings against Google Analytics after the invalidation of the Privacy Shield

The Schrems II ruling sparked a series of legal issues and decisions by European Data Protection Authorities (DPAs), which declared the use of Google Analytics as noncompliant with the GDPR.

A week before the Austrian ruling, the European Data Protection Supervisor (EDPS) sanctioned the European Parliament for using Google Analytics on its COVID testing sites due to insufficient data protections. This is viewed as one of the earliest post-Schrems II rulings and set the tone for additional legal complaints.

The EU-U.S. Data Privacy Framework

On July 10, 2023, the European Commission adopted its adequacy decision for the EU-U.S. Data Privacy Framework, which covers data transfers among the EU, European Economic Area (EEA) and the US in compliance with the GDPR.

The framework received some criticism from experts and stakeholders. Some privacy watchdogs, including the European Data Protection Board (EDPB), pointed out striking similarities between the new and the previous agreements, raising doubts about its efficacy in protecting EU residents’ data.

As of early 2025, the EU-U.S. Data Privacy Framework and adequacy for EU/U.S. data transfers are in jeopardy. President Trump fired all of the Democratic party members of the Privacy and Civil Liberties Oversight Board (PCLOB). As a result, the number of PCLPB board members is below the threshold that enables the PCLOB to operate as an oversight body for the EU-U.S. Data Privacy Framework.

This action will likely undermine the legal validity of the Framework for EU authorities, particularly the courts. The EU Commission could withdraw its adequacy decision for the EU-U.S. Data Privacy Framework, which would invalidate it. The Court of Justice of the EU (CJEU) could also overturn the Commission’s adequacy decision following a legal challenge. The last option is how the preceding agreements to the Framework were struck down, e.g. with Schrems II. 

Should the EU-U.S. Data Privacy Framework be struck down, it could have significant effects on data transfers, cloud storage, and the function of platforms based outside of the EU, like those from Google, including Analytics. At the very least, Google may be required to make further changes to the function of tools like Google Analytics, along with related data storage, to meet European privacy standards.

Google Analytics GDPR compliance?

Google Analytics 4 has several significant changes compared to Universal Analytics. The new version adopts an event-based measurement model, contrasting the session-based data model of Universal Analytics. This shift enables Google Analytics 4 to capture more granular user interactions, better capturing the customer journey across devices and platforms. Website owners can turn this off to stop it from collecting data such as city or latitude or longitude, among others. Website owners also have the option to delete user data upon request.

Another notable feature is that Google Analytics 4 does not log or store IP addresses from EU-based users. According to Google, this is part of Google Analytics 4’s EU-focused data and privacy measures. This potentially addresses one of the key privacy concerns raised by the Data Protection Authorities, which found that anonymizing IP addresses was not an adequate level of protection.

The EU-U.S. Data Privacy Framework alone doesn’t make Google Analytics 4 GDPR-compliant. The framework can make data transfers to the US compliant, if they are with a certified US company, but the onus is on website owners to ensure that the data was collected in compliance with the legal requirements of the GDPR in the first place.

How to make Google Analytics GDPR compliant

All Google Analytics cookies should be set up and controlled so they only activate after users have granted explicit consent. Users should also have granular control so that they can choose to allow cookies for one purpose while rejecting cookies for another.

A consent management platform (CMP) like Usercentrics can enable blocking of the activation of services until user consent has been obtained. Google Analytics couldn’t transfer user data because it would never have collected it.

Google Consent Mode allows websites to dynamically adjust the behavior of Google tags based on the user’s consent choices regarding cookies. This feature ensures that measurement tools, such as Google Analytics, are only used for specific purposes if the user has given their consent, even though the tags are loaded onto the webpage before the cookie consent banner appears. By implementing Google Consent Mode, websites can modify the behavior of Google tags after the user allows or rejects cookies so that it doesn’t collect data without consent.

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Website operators must provide clear, transparent data processing information for users on the website. This information is included in the privacy policy. Information related specifically to cookies should be provided in the cookie policy, with details of the Google Analytics cookies and other tracking technologies that are used on the site, including the data collected by these cookies, provider, duration and purpose. The cookie policy is often a separate document, but can be a section within the broader privacy policy.

The GDPR requires user consent to be informed, which is what the privacy policy is intended to enable. To help craft a GDPR-compliant privacy policy, extensive information on the requirements can be found in Articles 12, 13 and 14 GDPR.

4. Enter into a Data Processing Agreement with Google

A data processing agreement (DPA) is a legally binding contract and a crucial component of GDPR compliance. The DPA covers important aspects such as confidentiality, security measures and compliance, data subjects’ rights, and the security of processing. It helps to ensure that both parties understand their responsibilities and take appropriate measures to protect personal data. Google has laid down step-by-step instructions on how to accept its DPA.

Can server-side tracking make Google Analytics more privacy-friendly?

Server side tracking allows for the removal or anonymization of personally identifiable information (PII) before it reaches Google’s servers. This approach can improve data accuracy by circumventing client-side blockers, and it offers a way to better align with data protection regulations like the GDPR. By routing data through your own server first, you gain more control over what eventually gets sent to Google Analytics.

Impact of the Digital Markets Act on Google Analytics 4


The implementation of the Digital Markets Act (DMA) has had some impact on Google Analytics 4, affecting functions, data collection practices, and privacy policies. Website owners who use the platform have been encouraged to take the following steps for ongoing compliance.

  1. Audit your privacy policy, cookies policy and data practices.
  2. Conduct a data privacy audit to check compliance with GDPR, and take any corrective steps if necessary.
  3. Install a ​​CMP that enables GDPR compliance to obtain valid user consent per the regulation’s requirements.
  4. Seek advice from qualified legal counsel and/or a privacy expert, like a Data Protection Officer, on measures required specific to your business.

Learn more about DMA compliance.

How to use Google Analytics 4 and achieve GDPR compliance with Usercentrics CMP

Taking steps to meet the conditions of Art. 7 GDPR for valid user consent, website operators must obtain explicit end-user consent for all Google Analytics cookies set by the website. Consent must be obtained before these cookies are activated and in operation. Using Usercentrics’ DPS Scanner helps identify and communicate to users all cookies and tracking services in use on websites to ensure full consent coverage options. 

Next steps with Google Analytics and Usercentrics

Google Analytics helps companies pursue growth and revenue goals, so understandably, businesses are caught between not wanting to give that up, but also not wanting to risk GDPR violation penalties or the ire of their users over lax privacy or data protection.

The Usercentrics team closely monitors regulatory changes and legal rulings, makes updates to our services and posts recommendations and guidance as appropriate. 

However, website operators should always get relevant legal advice from qualified counsel regarding data privacy, particularly in jurisdictions relevant to them. This includes circumstances where there could be data transfers outside of the EU to countries without adequacy agreements for data privacy protection.

As the regulatory landscape and privacy compliance requirements for companies are complex and ever-changing, we’re here to help.

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The Interactive Advertising Bureau (IAB) launched the Global Privacy Platform (GPP) in 2022, a project of, and part of the portfolio of solutions from, the IAB Tech Lab’s Global Privacy Working Group. The GPP is the result of significant collaboration among industry stakeholders, including leading tech companies and tech experts around the world.

In line with aspects of the evolution of data privacy, the GPP enables streamlined transmission of signals from websites and apps to ad tech vendors and advertisers. This includes consent, preferences, permissions, and other relevant and often legally required information that affects data handling tools and processing. We look at how this tool can benefit publishers as data privacy compliance requirements expand and evolve, especially across digital marketing platforms.

What is the Global Privacy Platform (GPP)?

The GPP provides a framework for publishers that works similarly to the TCF or Google Consent Mode. Where Consent Mode signals consent information to Google services’ tags to control use of cookies and trackers, the GPP is a protocol that enables simple and automated communication of users’ consent and preference choices via a signal to third parties like ad tech vendors. 

The GPP enables advertisers, publishers, and technology vendors in the digital advertising industry to adapt to regulatory demands over time and across markets. It employs a GPP String, which encapsulates and encodes transparency details and consumer choices (like granular consent) as applicable to each region, helping enable compliance with privacy requirements by jurisdiction.

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How does the GPP signal work?

Digital property owners, like companies running websites or apps, are responsible for generating, transmitting, and documenting the GPP String and the information it sends. This enables data integrity and contributes to compliance.

Usercentrics CMP generates and manages the GPP String in an HTTP-transferable and encoded format. Ad tech vendors receive user choice information for consent and preferences, and can decode the GPP String to determine compliance requirements and status for each user. 

The format’s flexibility enables granular regulatory coverage, e.g. state-specific strings for the US where data privacy laws are in effect. The GPP covers 15 states as of early 2025, and five more are expected to get coverage this year. Country and regional strings like for the US and EU are also supported, as are non-geographic signals like those from Global Privacy Control, which are browser-based, with recognition of them to date only required by some laws.

The GPP is designed to evolve as the data privacy and regulatory landscape does, not requiring significant redevelopment when requirements change. The IAB Tech Lab’s Global Privacy Working Group handles the ongoing work of the GPP’s technical specification.

Why do publishers and others in ad tech need the GPP?

The majority of the world’s population is now covered by at least one data privacy law. Some regions, like the European Union, have multiple laws that intersect in various ways. Additionally, these regulations affect major tech platforms, which are adopting more stringent requirements for their customers to enable privacy-compliant ecosystems. This has significant effects on digital advertising, as major players like Google and Facebook adapt their operations and requirements. 

Additionally, in the United States, there isn’t one federal law to comply with. To date the data privacy laws are state-level, so a company could have to comply with one or ten or more as the regulatory landscape continues to evolve. However, many of these US regulations are fairly similar, which does support the “US National” signaling approach. Companies need tools, like a consent management platform and the Global Privacy Platform, designed to evolve with changes and expansion in regulations.

The GPP is designed for flexibility and scalability. It supports all current privacy signals and will be able to support future ones as new laws are passed and existing ones evolve. The architecture is designed to grow with companies’ operations, enabling publishers to better respect users’ privacy choices and more effectively signal them to vendors and partners.

Does the GPP affect the TCF?

The GPP isn’t the IAB’s first framework for publishers and ad tech. The Transparency & Consent Framework (TCF) was launched in 2018, the same year the EU’s General Data Protection Regulation (GDPR) came into effect. As of 2024, the TCF is now at version 2.2.

The GPP is designed to better meet the needs of publishers that need to signal consent across multiple jurisdictions, as many companies doing business around the world — or across the United States — need to do.

The plan is to ensure that updates made to the TCF over time are also reflected in the GPP, giving companies the best tools to achieve and maintain compliance with their digital advertising operations. Eventually, the goal is for the Global Privacy Platform — as the name suggests — to be the single framework for consent and preference signaling.

In Europe and the UK, Google will continue to use the TCF and will not be accepting the GPP signal. Using Ad Manager will still require the use of a certified consent management platform integrated with the TCF. TCF strings sent through the GPP won’t be accepted.

What is the multi-state privacy agreement (MSPA) and how does the GPP affect it?

The Multi-State Privacy Agreement (MSPA) is an industry-centric contractual framework for companies doing business in the US, which covers 19 states as of early 2025. It’s meant to “aid advertisers, publishers, agencies, and ad tech intermediaries in complying with five state privacy laws.” The IAB Tech Lab is prioritizing updates to MSPA/US National before providing further state-specific strings, though that’s expected later in 2025. 

The MSPA evolved from the IAB’s Limited-Service Provider Agreement (LSPA), from 2020 and focused on CCPA/CPRA compliance initially. The evolution has focused on legal standards and protecting consumers’ privacy rights, and working with the GPP (including the specific privacy strings for each state). The MPSA is also designed for flexibility and scalability as US data privacy challenges become more complex.

The Global Privacy Platform currently supports various privacy signals around the world, both for their own frameworks and external ones. Some US state-level data privacy laws require recognizing a universal opt-out mechanism like Global Privacy Control, but not all of them.

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GPP and international privacy laws

The Global Privacy Platform was designed to address the increasing complexity of data privacy regulation and requirements. Many companies do business across international jurisdictions and have many partners and vendors that they work with. This is only going to increase.

GPP and the GDPR

Europe has led the way in modern data privacy with the GDPR, TCF, and other relevant regulations and frameworks. It was the IAB Europe that brought the TCF to the market, and the GPP supports the EU TCF v2 signal. As noted, Google does not currently support the TCF via the GPP, so until industry adoption changes, this implementation isn’t recommended.

One of the main goals of the TCF was to help organizations meet GDPR compliance requirements, and the GPP is meant to extend this mandate.

GPP and PIPEDA

In Canada data privacy is governed by the Personal Information Protection and Electronic Documents Act (PIPEDA), which has been in effect since 2000, and a lot has changed since then. There are a number of requirements in PIPEDA and Quebec’s Law 25 that the GPP helps with, and the Platform already does support the CA TCF signal. Here are some of the benefits.

GPP and US privacy laws

The patchwork of data privacy laws and requirements in the US was a major factor in building out the Global Privacy Platform. As of the end of 2024, 21 data privacy laws have been passed by US state-level governments, which can introduce a lot of complexity into doing business. 

The IAB Tech Lab created the US Privacy Specifications, which have been used to support the CCPA Compliance Framework. However, a lot more laws have been passed since the CCPA came into effect. As of 2023, the US Privacy Specifications are not being updated, and have been replaced by state-specific privacy strings available via the GPP.

However, IAB MSPA US National also provides a national approach to privacy compliance with state-level laws by utilizing the highest standard. 

Additionally, the GPP is designed to evolve and scale with further data privacy regulatory requirements in the US, and to enable companies to manage consent and preferences with vendor relations in a streamlined way. This will also be relevant as more and more platforms evolve their data privacy requirements.

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How Usercentrics supports the Global Privacy Platform

Usercentrics currently supports the GPP and is working toward additional regulatory coverage. Direct support from the Consent Management Platform’s Admin Interface is also being developed, along with further enhancements. 

The Usercentrics CMP integrates with the GPP and generates the necessary GPP string to signal consent information.

Companies serving Google ads in the EU, EEA, or UK also continue to need a Google-certified CMP like Usercentrics CMP, which comes with the TCF v2.2 integrated, since, as noted, Google will continue to only support this format and is not accepting TCF strings sent through the GPP.

As complexity and requirements for data privacy continue to evolve, and as individuals become more invested in their privacy and choice, it’s never been more important to invest in reliable, scalable tools to obtain, manage, and signal valid consent — in every region where you do business. It’s becoming a key competitive advantage to grow trust and revenue.

As more and more digital platforms adapt to regulatory requirements as well, your company’s international advertising operations will increasingly depend on how well you’ve implemented consent and preference management with tools like Usercentrics CMP and the Global Privacy Platform. The era of Privacy-Led Marketing is here, and Usercentrics has the tools to help you embrace it and grow with confidence.

In 2019, New York’s data breach laws underwent significant changes when the SHIELD Act was signed into law. The regulation has continued to evolve, with new amendments in December 2024. This article outlines the SHIELD Act’s requirements for businesses and protecting and handling New York state residents’ private information, from security requirements to breach notifications.

What is the New York SHIELD Act?

The New York Stop Hacks and Improve Electronic Data Security Act (New York SHIELD Act) established data breach notification and security requirements for businesses that handle the private information of New York state residents. The law updated the state’s 2005 Information Security Breach and Notification Act with expanded definitions and additional safeguards for data protection.

The New York SHIELD Act introduced several requirements to protect New York residents’ data. These include:

The law also increased penalties for noncompliance with its data security and breach notification requirements.

The New York SHIELD Act was implemented in two phases: 

Who does the New York SHIELD Act apply to?

The New York SHIELD Act applies to any person or business that owns or licenses computerized data containing the private information of New York state residents. It applies regardless of whether the business itself is located in New York. This scope marked a significant expansion from the previous 2005 law, which only applied to businesses operating within New York state. The law’s extraterritorial reach means that organizations worldwide must comply with its requirements if they possess private information of New York residents, even if they conduct no business operations within the state.

What is a security breach under the New York SHIELD law?

The New York SHIELD Act expanded the definition of a security breach beyond the 2005 law’s limited scope. The previous law only considered unauthorized acquisition of computerized data as a security breach. The New York SHIELD Act includes the following actions that compromise the security, confidentiality, or integrity of private information:

The law provides specific criteria to determine unauthorized access by examining whether an unauthorized person viewed, communicated with, used, or altered the private information.

What is private information under the New York SHIELD Act?

The New York SHIELD law defines two types of information: personal and private.

Personal information includes any details that could identify a specific person, such as their name or phone number.

Under the 2005 law, private information was defined as personal information concerning a natural person combined with one or more of the following: 

The New York SHIELD Act expands this definition of private information to include additional elements:

The law specifically states that publicly available information is not considered private information.

This definition is set to expand once again. On December 21, 2024, Governor Kathy Hochul signed two bills that strengthened New York’s data breach notification laws. Under one of the amendments, effective March 21, 2025, private information will include:

What are the data security requirements under the New York SHIELD Act?

This New York data security law requires any person or business that maintains private information to implement reasonable safeguards for its protection. There are three categories of safeguards required: administrative, technical, and physical.

Administrative safeguards include:

Technical safeguards include:

Physical safeguards include:

Businesses are deemed compliant with these safety requirements if they are subject to and compliant with certain federal laws, such as the Gramm-Leach-Bliley Act (GLBA), the Health Insurance Portability and Accountability Act (HIPAA), and the Health Information Technology for Economic and Clinical Health Act (HITECH).

What are the data breach notification requirements under the New York SHIELD law?

The New York SHIELD Act sets specific requirements for how and when businesses must notify individuals and authorities about data breaches involving private information.

The law previously required businesses that discover a security breach of computer data systems containing private information to notify affected consumers “in the most expedient time possible and without unreasonable delay.” The December 2024 amendment added a specific timeline to this requirement. Businesses now have a maximum of 30 days in which to notify affected New York state residents of data breaches. The 30-day time limit came into effect immediately upon the bill being signed.

The New York SHIELD Act also previously required businesses to notify three state agencies about security breaches: 

The December 2024 amendment added a fourth state agency to be notified, with immediate effect: the New York State Department of Financial Services. 

These notices must include information about the timing, content, distribution of notices, and approximate number of affected persons, as well as a copy of the template of the notice sent to affected persons. If more than 5,000 New York state residents are affected and notified, businesses must also notify consumer reporting agencies about the timing, content, distribution of notices, and approximate number of affected persons.

The law introduced specific restrictions on methods for notifying affected consumers. Email notifications are not permitted if the compromised information includes an email address along with a password or security question and answer that could allow access to the online account.

All notifications must provide contact information for the person or business notifying affected persons as well as telephone numbers and websites for relevant state and federal agencies that offer guidance on security breach response and identity theft prevention.

Enforcement of the New York SHIELD Act and penalties for noncompliance

The New York Attorney General has the authority to enforce the New York SHIELD Act, with the power to pursue injunctive relief, restitution, and penalties against businesses that violate the law.

The law establishes different levels of penalties based on the nature and severity of the violations. When businesses fail to provide proper breach notifications, but their actions are not reckless or intentional, courts may require them to pay damages that cover the actual costs or losses experienced by affected persons.

More severe penalties apply to knowing and/or reckless violations of notification requirements. In these cases, courts can impose penalties of up to USD 5,000 or USD 20 per instance of failed notification, whichever amount is greater. These penalties are capped at USD 250,000.

Businesses that fail to implement reasonable safeguards as required by the law face separate penalties. Courts can impose fines of up to USD 5,000 for each violation of these security requirements.

Impact of the New York SHIELD Act on businesses

The New York SHIELD law imposes significant obligations for any organization handling New York residents’ private information, regardless of location. Businesses must implement comprehensive data security programs with specific safeguards, meet strict breach notification deadlines, and prepare for expanded data protection requirements.

Key impacts include:

New York SHIELD Act Compliance Checklist

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Below is a non-exhaustive checklist to help your business comply with the New York SHIELD Act. For advice specific to your organization, it’s strongly recommended to consult a qualified legal professional.

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The Norwegian Electronic Communications Act (E-com Act / Ekomloven) has been updated, effective January 1, 2025. This follows the Norwegian Parliament (Stortinget) adopting a proposal submitted by the Norwegian Ministry of Digitalisation and Public Governance in November 2024. Previously, Norway’s cookie use and consent requirements were notably more lax than European standards.

The revision better aligns Norwegian regulation of cookie use with the GDPR and ePrivacy Directive (though Norway is not an EU Member State). It introduces stricter standards for obtaining and managing user consent for use of cookies and other tracking technologies.

Norway also has the Personal Data Act to protect data and privacy when data processing occurs, with oversight and enforcement by the Norwegian Data Protection Authority (Datatilsynet).

The updated guidelines affect all businesses operating websites or applications that have or target Norwegian users, so both Norway-based businesses and international companies with platforms, products, or services used by Norwegians.

Specific platforms and parameters that will be affected:

The E-comm Act’s consent requirements are now aligned with the stricter consent standards of the GDPR. Like in Art. 4(11) GDPR, consent must be “freely given, informed, specific, and unambiguous.” 

Active/explicit consent is mandatory, so users must perform a specific action to indicate giving consent. Ignoring a consent banner being construed as consent, or passive actions like pre-checking boxes or using browser settings is not allowed. Previously, some passive actions were acceptable under the law.

Businesses must also enable users to modify or withdraw previously granted consent at any time. The tools to do so must also be user-friendly to be compliant with the law’s requirements.

Only cookies or tracking technologies classified as “strictly necessary” can be used to collect data without obtaining user consent. What qualifies has been refined and now only includes cookies required for the basic operation of a website or app, e.g. shopping cart functionality or maintaining an active login session.

Analytics, marketing, and user preference cookies are not strictly necessary and do require valid user consent prior to being activated. 

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The law does not specify what the lifespan of cookies is allowed to be, but does require transparency from businesses about the cookies and trackers in use, including what data is collected and for what purposes, how long it will be retained, what parties it may be shared with, and what users’ rights are and how they can exercise them.

Additionally, companies that meet the law’s criteria must deploy a cookie consent banner that meets new guidelines’ requirements. There must be mechanisms to equally enable users to consent to cookie use or decline it, as well as to manage consent at a granular level, and to easily modify or withdraw it.

Companies must provide information about cookie use and consent in an easily accessible way on their website or app, including the E-com Act’s rules for cookie use, and details about which cookies or other tracking technologies are in use, what data is processed and why, and the processor’s identity.

Websites must remain accessible to users who refuse cookies, so cookie walls are not allowed, though it is acceptable for some functionality to be reduced slightly if a user declines cookies.

Companies also need to document and securely store users’ consent information over time, and be able to provide it in the event of a data request or audit.

Businesses that are already GDPR-compliant are already well positioned for compliance with the Norwegian cookie guidelines as well.

Companies operating websites and apps that do not comply with the new guidelines risk daily fines and government orders to improve their compliance activities. Fines can be up to 5 percent of the business’s total sale revenue for the preceding year, depending on how long the violation has been going on and how serious it is.

Compliance is overseen by the Norwegian Communications Authority (NKOM) and Norwegian Data Protection Authority (Datatilsynet).

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Usercentrics has been enabling ongoing data privacy compliance since the GDPR was implemented. In addition to helping companies to meet their legal obligations, Usercentrics Web CMP and Usercentrics App CMP enable you to deliver better transparency and great user experience. 

Collect, securely store, and document valid user consent that meets Norwegian, EU, and/or international regulatory requirements while building trust with your users, helping you get the data you need and growing engagement and revenue.

Setup is designed for ease of use for technical and non-technical teams. Use one of our high quality pre-built templates, or fully customize your consent banner to match your brand. 

Our powerful scanning technology detects and automates categorization of the cookies and tracking technologies you’re using, and we provide over 2,200 legal templates for data processing services in use, saving your time and resources at implementation and maintenance. A/B testing and in-depth analytics help you understand user interactions and consent choices to optimize your banner for higher consent rates.

Plus, you always get our expert guidance and detailed documentation every step of the way, so you can stay focused on your core business and harness the competitive advantage of Privacy-Led Marketing.

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