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GA & your responsibilities

• Managing accounts, properties, user access and data. It is a requirement under the Observatory Terms of Service to regularly review accounts and properties.
• Ensuring that information captured in Google Analytics is not personally identifiable and that all employees and contractors comply with the Australian Privacy Principles and obligations under the Privacy Act 1988 (Cth).
• Following the Observatory Terms of Service, Google Analytics Terms of Service and Google Cloud Platform Terms of Service information relating to privacy.
• Undertaking an independent privacy threshold / impact assessment.
• Compliance with the Information Security Manual (ISM), which includes not storing personal or sensitive information on Google Analytics or Google Cloud Platform Services, and protecting information from cyber threats.
• Google is constantly changing and while we do our best to keep you informed, it is your responsibility to monitor for product, privacy and security updates which may impact your privacy and security assessments and agency risk tolerance.

PII is any information that could be used on its own to directly identify, contact, or precisely locate an individual. This includes:

• Email addresses
• Mailing addresses
• Phone numbers
• Precise locations (such as GPS coordinates)
• Full names or usernames

PII may also include other types of information that are considered personal or sensitive under the Australian Privacy Act, such as:

• A person’s name, signature, home address, email address, telephone number, personal IP address, date of birth
• Health information, bank account details, credit information and employment details
• ‘Sensitive information’ (includes information or opinion about an individual’s racial or ethnic origin, political opinion, religious beliefs, sexual orientation or criminal record, provided the information or opinion otherwise meets the definition of personal information)

Why you should care:

• You are obligated to comply with the Privacy Act, as previously discussed, and to protect user privacy
• Google policies mandate that no data be passed to Google that Google could use or recognise as PII
• Continued collection of PII data in a GA4 property can result in suspension and/or permanent deletion of that property by Google
• As such, it’s crucial you regularly check your property for PII and delete any data that may contain it

In GA4, PII may occur in:

• Page URLs and titles
• Campaign (UTM) dimensions (e.g. Source, Medium, Keyword, Campaign, Content, Term)
• Site search dimensions
• Event dimensions (e.g. Event Name and Event Parameters)
• Any other fields where users can input information, and this is sent to GA4
• Custom dimensions, if using
• User IDs, if using
• Data imports, if using

As GA4 records all URLs visited by users, it will also record URLs that potentially have PII in them. This can happen on forms, or any sections of a website where the user is required to provide information. If the user submits PII such as their email address, name, etc. as part of a form submission, site search, and so on, that data may be sent to GA4 (within a page URL, an event or custom dimension, and so on). While on-site design features and GA configurations can be used to limit such vulnerabilities, individual agency Privacy Notices should clearly outline the type of data that could be collected, and also call out any potential inadvertent mechanisms for data collection.

To access the data deletion feature in GA4, you need to have Editor or Admin access to the property. You can check your access level by going to Admin > Data Deletion Requests. If the option is greyed out, you do not have the required access level.

If you have the required access level, you can click on Data Deletion Requests and then click on Schedule Data Deletion Request to start the process.