Google Privacy and Restricted Data Processing

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Google recently made some updates to its privacy policy regarding personalized advertising and restricted data processing.

While I recommend you give this article a read to get a high level overview of what’s happening, there’s a bit more going on here. Sifting through multiple documents written in legalese can be quite the headache, so I’ve consolidated the major implications that advertisers are facing from this change below.

What’s Changed

The impetus for this change is Colorado’s universal opt-out shortlist policy going into effect on 7/1/24. This policy basically states that if a consumer elects to opt out of allowing their data to be used for personalized advertising through a third party such as Global Privacy Control, then advertisers and their respective data processors must respect this decision.

In other words, someone doesn’t have to go to your site and specifically opt out of your brand using their data, theyy can make a universal decision to prevent all brands from using their data for personalized advertising.

As a result, if you enable restricted data processing (RDP) within Google Ads, Google will automatically ingest these signals from tools like Global Privacy Control, and remove users who have opted out from any personalized advertising efforts on your behalf.

This makes privacy compliance easy for advertisers using Google Ads, but there are a few performance implications.

What Are The Implications

The largest and most obvious implication is that pixel-based features like audiences created off of site visitors will begin to lose effectiveness. This isn’t necessarily anything new, but the impact may be more significant.

When Apple rolled out their app tracking transparency protocol, I saw site visitor retargeting audiences on Meta experience a steep decline in size and quality. Time will tell if the magnitude of impact will be the same on Google, but it might be worth preparing for the worst.

In addition to the impact to site visitor audiences, customer match lists will also now be subject to comply with RDP. That means even if you’ve captured someone’s email, they can opt out of personalized advertising via Global Privacy Control and Google will remove their data from your customer match list.

I find this change to be interesting given how hard Google has been pushing advertisers to lean into first party data with the eventual deprecation of third party cookies. It seems as if now even some first party data tactics won’t be as effective come July 1st.

With that said, this isn’t all doom and gloom, there are a few simple ways for advertisers to adjust to these changes.

What Can You Do About It

The first opportunity I’ll be exploring with clients will be diversifying our channel mix. Google Ads isn’t the only platform where it’s possible to leverage retargeting audiences, so leaning into platforms like Meta or LinkedIn are easy ways to market to leads using first party contact lists.

However, expanding channels doesn’t only mean expanding paid media channels. If other platforms begin to adopt a similar privacy approach to Google (which I imagine they will), then even first party customer lists may lose their effectiveness in these platforms. This is where leaning further into email marketing can provide a big opportunity.

Collecting contact information from prospects and following up with value-first educational content via email can be a great way to help these potential future customers conduct the research they need in order to feel confident making a purchase.

This dynamic might also require marketers to change what we expect out of paid media campaigns. If it becomes more difficult to target users who have shown high-intent purchase signals via paid, then the role of ads might have to be more focused on building awareness and introducing prospects to your brand. From there, other channels like email and organic might have to do the heavy lifting to guide customers along their buyer journey.

I believe that not all ads should be measured against their direct impact to revenue, but these privacy changes could be another important force in driving that change.

Wrapping Up

Recent changes in state-level policies have driven Google to adopt a more consumer-first privacy approach to how individual user data is handled within Google Ads.

This will have an impact on the effectiveness of audiences when using both first and third party data. However, exploring other channels, including those outside of paid media, can help marketers to adjust their strategies and mitigate any loss in overall performance.

I’m not a lawyer so I definitely recommend you consult with a legal resource if you have any questions here, but I hope that this helps to outline some opportunities from a marketing perspective as these changes are quickly approaching!

Have questions, considerations, or critiques? I’d love to hear them! If you’re reading this via email, just hit respond. Otherwise, you can find me on LinkedIn.

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