Important
The Hybrid Measure only applies to certain markets that have an exemption from consent for the deposit of audience measurement trackers.
It is based in the ePrivacy exemption, the provisions of which are set out in Article 5 of CNIL deliberation n° 2020-091 of 17 September 2020 (guidelines) for France.Definition
In accordance with the GDPR and the ePrivacy directive, the processing of personal data for Analytics requires the prior consent of the visitor.
An exception exists in some European countries: the ePrivacy Exemption.
The Hybrid Measure is a combination of 2 systems: browsing begins in ‘exemption’ and passes to full Analytics once visitor consent is obtained. This method has been approved by the CNIL.
Therefore:
- It is possible to obtain user consent, contrary to the ePrivacy exemption only: the visitor thus passes from an ‘exempt’ status to an ‘opt-in’ status.
- The ‘user’ ID, personal data and more generally all your Analytics data may be sent in the case of shift to opt-in.
These key principles enable you to fully assess the potential of Analytics Suite and the ePrivacy exemption.
Advantages
With the hybrid measure, your visitors are neither lost nor duplicated prior to consent and you obtain high-quality data.
You may collect the data which is strictly necessary to the provision of your services.
Once you have obtained your visitors’ consent, they can be identified as users and you may extract their data or collect personal data.
In this way, you can collect the most complete and comprehensive data!
Risks
Contrary to other methods, there is no known risk.
Important
The CNIL exemption is a prerequisite for the hybrid measure. Consequently, the hybrid measure is reserved to the French market.
Please ensure you validate its use with your legal teams prior to implementation.
Expected behaviour
To comply with your users’ wishes, you must be able to modify the state of consent at any time of the visit.
Step | Description | |
Arrival on the site |
Visitor identification is authorised and dedicated cookies may be placed (idrxvr,atidx,atid or atuserid) |
|
Visitor chooses |
Visitor identification is authorised and dedicated cookies placed on the first page remain in use (idrxvr,atidx,atid or atuserid). |
|
Visitor chooses |
All cookies are defined with the OPT-OUT value. |
Tagging configuration
The ‘hybrid measure’ method will use the Tag Composer Privacy plug-in available in the Javascript 5.24.0 version.
Please ensure you implement the correct version of the marker in order to collect only such data as is strictly necessary in exempt mode.
Prerequisites
This plug-in and its methods apply solely to client-side visitor identification, it will impact first-party cookies only.
Tagging
To handle visitor consent in the Hybrid Analytics marking, you simply need to add a line to the beginning of your SmartTag tagging.
Then, just move from one state to another depending on the consent expressed by the visitor.
Exempt
var tag = new ATInternet.Tracker.Tag();
tag.privacy.setVisitorMode('cnil', 'exempt'); // Visitor set under Exempt
tag.page.set({
name: 'pageName',
});
tag.dispatch();
Here, the marker will only collect data which is strictly necessary and common to all forms of activity:
s | idclient | vm | vc | ts | vtag | ptag | p | type | click |
site number | visitor identifier | visitor mode | visitor consent | hit timestamp | tag version | platform using the tag | page label | hit type | click type |
If you wish to add settings to feed properties which you consider to be essential to your activity, you may add them to the marker or via Tag Composer.
All information will be presented in the developer documentation.
Opt-In
var tag = new ATInternet.Tracker.Tag();
tag.privacy.setVisitorOptin(); // Visitor set under Opt-In
tag.page.set({
name: 'pageName',
});
tag.dispatch();
Opt-Out
var tag = new ATInternet.Tracker.Tag();
tag.privacy.setVisitorOptout(); // Visitor set under Opt-Out
tag.page.set({
name: 'pageName',
});
tag.dispatch();
It is possible not to send information by using the false setting of Tracker sendHitWhenOptOut.
Certification
Setting up the CNIL Exemption also reduces the loss of trafic on certified analysis (ACPM).
To make sure your tagging is fit for certification purposes, please specify the following properties on your responsive site: customObject = {"device":"APPsmartphone"}, and customObject = {"device":"APPtablet"}.
Properties
Consent properties
The new Privacy plug-in methods add 2 properties to your hits:
- Visitor mode: visitor_privacy_mode / &vm to filter events based on the consent status (exempt/optin/optout)
- Visitor consent: visitor_privacy_consent / &vc to directly identify consented traffic when ‘true’
Data which is not strictly necessary
User identification, for example, is only available when the visitor mode is in opt-in.
Even if it is placed on the same page marker, only the opt-in method will authorise the addition of properties to hits.
var tag = new ATInternet.Tracker.Tag();
tag.privacy.setVisitorMode('cnil','exempt'); // Visitor set under Exempt
tag.page.set({
name: 'pageName',
});
tag.identifiedVisitor.set({
id: 123456 // Non transmis, du fait du mode visiteur défini en Exempt
});
tag.dispatch();
The same applies to all data which is not deemed strictly necessary by our Privacy team.
As Data Controller, the choice is nevertheless yours to make. You will therefore be able to specify directly in the marker or Tag Composer which settings you wish to ‘authorise’ in order to feed your analysis in exempt mode.
Explorer
Once the marking is implemented and the properties have been added to the hits, you will be able to add to your Explorer analyses with the ‘Combine’ button above each table.
You will then be able to filter property values (visitor mode: exempt/opt-in, visitor consent: true/false).
Privacy analysis
In Explorer you can reach Audience > General Traffic > Privacy to see the number of events considered as opt-out.
When the visitor has opt-out status, their data is anonymised, excluded from general traffic and serves only to feed this analysis.
You may also see a Privacy status entitled ‘No cookie browser’.
This represents events where the cookie has not been placed, due to the browser setting for cookie placement.
Data Query / Data Flow
You may add the Visitor mode and Visitor consent properties to your data sets.
You can also consult the user ID and personal data, by using the visitor mode filtered via the opt-in value.
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