What your charity needs to know about Google Consent Mode v2

24 April 2024  |  Stuart Palmer

If you use Google Analytics or Google Ads on behalf of your charity, you have probably come across Google Consent Mode v2.

Even if you haven’t, it’s important that anyone responsible for data protection has a basic idea of what Consent Mode v2 is and whether they need to take immediate action to avoid losing donations or worse – incurring fines!

Google, Consent Mode v2 and the European Union

In a nutshell, Consent Mode v2 is Google’s way of ensuring they are compliant with the Digital Markets Act Regulation (DMA) 2022.

In turn, the DMA was the European Union’s response to concerns over how its citizens’ data is used by global digital platforms. It applies across the European Economic Area (EEA) and also to the UK, so even if your charity operates nationally, you may need to act.

The EU identified Alphabet (Google’s parent company) as one of six ‘gatekeepers’ that had until 6th March 2024 to implement the DMA.

To simplify what can be a very complicated technical subject, your charity’s digital platforms (websites, apps, etc.) will currently be in one of three states.

• Not using Consent Mode v2
• Using Advanced Consent Mode v2
• Using Basic Consent Mode v2

Does your charity need to use Consent Mode v2?

First, Consent Mode v2 only applies to Google products, so if you don’t use Google Analytics, Google Ads or Google Tag Manager, it doesn’t apply.

However, DMA 2022 certainly does apply, so we recommend reading the rest of this article (especially the last section) so you can ensure your general data collection behaviour is compliant.

If you do use Google Ads and/or Google Analytics, then not enabling Consent Mode v2 will effectively turn off user data collection from all of your websites and apps. You will lose granular insights about who is visiting your website, and Google will be unable to populate remarketing lists or create accurate lookalike audiences. Your ad campaign performance will drop and ads may even become ineligible.

You may be able to perform basic conversion tracking, but this will be limited, especially when it comes to visitors from the EEA or regions, such as California, with strict privacy regulations. In any case, your conversions will likely drop due to poor audience targeting.

Before we show you how to enable Consent Mode v2, let’s look at whether Basic or Advanced Consent Mode is best for your charity.

Basic or Advanced Consent Mode: which is best?

There is lively debate about whether organisations should be using Advanced or Basic Consent Mode – and with good reason. While Basic Consent Mode is a simple yes/no way of controlling what data passes from your website to Google, Advanced Consent Mode takes a controversial position.

With Advanced Consent Mode enabled, some user data is sent to Google before they get the chance to opt in or out. How can that be? On a technical level, the ‘tags’ that are downloaded to your users device are initially loaded in a ‘restricted state’.

The user then gets the option to fine tune their preferences. They can choose to allow cookies for analytics but not for marketing (or vice versa). The cookies they have opted in to are then downloaded to their device. Where they have opted out of cookies, the relevant tags send ‘cookieless pings’ back to Google instead. These contain no user identifiers, but they do include high level data about browser type, location, etc. This is fed into machine learning models to help with analytics and data-driven ad campaigns.

Critics claim that this is a technical breach of DMA 2022, but this is how Advanced Consent Mode works right now, and it will enable your charity to have a bit more data to work with for gaining user insights and driving your Google Ads remarketing campaigns.

If you are uncomfortable with operating within this grey area of compliance, Basic Consent Mode might be a better option. In this mode, no tags are loaded unless and until a visitor explicitly opts in to cookies. Your analytics and retargeting data may be limited, especially if your audience is very privacy-conscious, but you can’t be accused of sharing your users’ data without consent. Since nurturing supporter trust is vital for charities, this may work in your favour.

Checking and implementing Google Consent Mode v2

The easiest way to check whether Google Consent Mode has been enabled is to ask your website developer or digital marketing team.

Alternatively, there are a few ways you can check this for yourself:

• Via Google Ads. Go to your ‘Conversions’ tab. Select your primary conversion action and check the ‘Diagnostic’ tab.
• Via Google Analytics (GA4). Go to the ‘Admin’ section of your account (usually on the bottom left), and click the link for ‘Data streams’ on the ‘Data collection and modifications’ panel. Select the relevant stream and expand the ‘Consent settings’ panel. If consent signals are not being detected, you have not yet enabled Google Consent Mode. See image below.
• Via Google Tag Manager (GTM). Select the container for your website or app and click the preview button. Connect to your site. This will bring up two panels: one displaying your website, and the other GTM’s Tag Assistant. Click the individual tags on Tag Assistant and select the ‘Consent’ tab. This will show you if consent has been configured or not.

If you need to implement Google Consent Mode v2, the simplest way is to use a Google-certified consent management platform (CMP). This Google article will help you find and integrate a reputable CMP: https://support.google.com/tagmanager/answer/14009343#web-consent

If you prefer to stick with your existing cookie notice, integration does get a bit more technical. We recommend involving your web development or technical team. Guidance from Google can be found here: https://developers.google.com/tag-platform/security/guides/consent?consentmode=advanced

Cookie consent for non-Google products

It is important for charities to understand that DMA 2022 goes beyond Google and the other five digital gatekeepers who have implemented similar consent mechanisms.

To comply with the regulation, any user who engages with your charity’s website or apps must be presented with the option to accept or reject analytics and marketing cookies.

Whether you use a Google-certified CMP to achieve this or create something bespoke, it is vital that you work with your developers or technical team to ensure the way your consent form works complies with the terms of DMA 2022.

Well done for sticking with us until the end. We’ve tried to avoid getting too technical, and we hope the take home message is clear: if you haven’t already, you really want to urgently enable Google Consent Mode v2!

Our suggested approach for Consent Mode V2 implementation

We have been using CookieYes (CY) and Google Tag Manager (GTM) to add compliance to our client sites. CookieYes has a free tier covering up to 25,000 page views per month which is suitable for many small charities. CY can be configured entirely in GTM, although it is crucial to get the tag and trigger settings correct to ensure no cookies are dropped prior to consent.

If you’d like us to update your website for Consent Mode V2 compliance, please get in touch.