Piano Analytics provides you with a set of tools to make your analytics solution compliant with the legislation you need to comply with.
This compliance requires perfect data governance to ensure the quality of the information you collect and manipulate.
In Piano Analytics, data governance is ensured by the "Contains personal data" flag.
"Contains personal data" flag
Every interaction from a platform you measure can be collected and associated with contextual information.
A page name, a device type, or even a date are all information we regularly find in analytics events.
Among this qualifying information (properties), some can be considered as requiring special attention:
- They may contain personal data, directly or indirectly (according to the GDPR)
- They may contain Personally Identifiable Information - PII (according to the US government)
- They may contain information that requires vigilance under any applicable legislation
For example, a "User ID" property containing the unique identifier of authenticated customers (collected with their consent) is both a personal data and PII.
In this case, you can add the "Contains Personal data" flag to this property from the Data Management interface to apply certain processing to it.
Effect of the flag on properties
Adding a "Contains Personal Data" flag to a property automatically performs a series of operations on that property. It is the sum of these operations that allows you to achieve compliance.
Data model governance
Once the flag is set on a property, it is assigned the technical metadata "contains personal data". This information is then propagated to all tools and APIs.
The first consequence is that you can quickly find properties that are considered to contain personal data in Data Management. A small icon appears next to the property name:
You can also filter for these properties in the data model filters:
This way, you always know how many properties in your data model require special attention, and which ones they are. You can also export your data model to get this information:
Property clean-up
A property with a "contains personal data" flag is subject to a special treatment designed to help you comply: property clean-up according to the consent mode.
By selecting a specific consent mode, you can choose to have Piano Analytics clean the property immediately after it is collected for that mode. This way, even in the event of a tagging error, you can be sure that the property will not be stored.
Add a flag on properties
To add a "Contains personal data" flag to a property, go to Data Management and open the panel for that property.
Simply check the "Contains personal data" toggle:
You can remove the flag by clicking the toggle again.
Note
Some properties cannot be associated with a "Contains personal data" flag because they are fundamental to the operation of the Analytics solution. Processing is not applicable. The concerned properties are "event_time", "event_time_utc", "site_id", "event_name"and "event_id".
Cleanup properties according to consent mode
Consent modes
Piano Analytics offers 3 consent modes by default:
- opt-in (my user has consented)
- essential (my user has not consented, but I have the ePrivacy exemption configuration)
- opt-out (my user has not consented)
The opt-out consent mode (strict by default) can be changed to "extended opt-out" by configuring your library. See the Extended Opt-Out article.
These three consent modes (+ extended opt-out) can be found on each event thanks to the 'visitor_privacy_mode' property, which takes one of the following 4 values
- optin
- exempt
- optout
- extended-optout
These are the values to be entered when setting up a cleanup on a dedicated property.
Cleanup a property
To clean up a property, first make sure it has the Contains Personal Data flag:
Next, go to the property's Processing tab and open the default rule for that property.
Note
Cleaning a property only applies to the default rule. It cannot be applied to a site or group of sites.Once on the property Processing page, you can interact with the Privacy Mode block, which allows you to add consent mode values to clean the property for that mode:
You can also remove added modes.
Limits on property cleanups
Extended opt-out
The "extended opt-out" consent mode cannot be removed from the Privacy Mode block. This means that all properties with the "contains personal data" flag will be cleared for the "extended opt-out" mode.
This ensures that the Extended Opt-Out collection does not contain any personal information, thereby enabling compliance with the RGPD.
See the Extended Opt-Out article for more information.
Properties limits
Some properties have a treatment for which it is not possible to change the processing rules:
- Calculated
- Enriched (retroactively)
In these two cases, the property is not fed by the tag and is therefore not processed. It is not possible to clean them with a "Contains personal data" flag.
Piano Analytics standard properties
Piano Analytics provides standard properties in your data model. Some of these properties contain personal information.
As a result, these properties natively benefit from the "Contains Personal Data" flag and are cleaned up in the "Extended Opt-Out".
You can find these properties by using the Privacy and Entities filters in Data Management.
As the data controller, you can remove the "Contains Personal Data" flag for standard properties.