Google Analytics - Prior Consent Needed even for the simplest approach?



  • Official comment
    Brian Mørkeberg Lundkvist

    Hi Edgar

    Looking at GDPR alone, cookies can be set and tracking can be done as long as it is anonymous and does not deal with any personal information. 

    It becomes more tricky when including the ePrivacy Directive as it varies in its interpretation in different member states. It is however stricter and generally doesn't allow ANY cookies being set before prior consent, other than those strictly necessary for the website to operate.

    Read more about this here: 

    We recommend that you check with your national Data Protection Authority for clarity into their specific interpretation. See more here: 

    Do keep in mind that the in process ePrivacy Regulation looks to become a reality early next year and it will take precedence over GDPR.


    With regards to cookies and tracking on we are compliant with regards to both GDPR and the ePrivacy Directive.

    We do not set GA related cookies and do not track visits until prior consent has been obtained.

    I do not recognize the behavior you are describing nor am I able to recreate it. If you navigate to in incognito or you visit the site after having cleared your cookies, you will not see GA cookies or calls to Google services other than GTM. In GTM we hold back analytics and everything else until consent is obtained.



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    Edgar F

    Thanks for the reply. I actually did check again the cookiebot site. You are right, at the very beginning, the GA cookies are not set, however - the second I start scrolling, those are triggered. Is it still meeting the requirements? As far as I know, consent should be explicit and scrolling action doesn't look like it.  

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