UserID - GDPR issue?

[priyankagupta20]

Dear Team,
The client wants to track the userID. Is there any GDPR compliance issue with this? If yes, how can we implement it step by step to ensure compliance and avoid any GDPR violations?

Please guide, thank you.

[bjoern__koth · Accepted solution]

Hi @priyankagupta20 

if you want to capture the User Id in a custom prop or eVar, make sure to label them accordingly. Side note: I have rarely come across GDPR requests from a website visitor, but the labels surely help.

In your case I presume it's an I2 category among others that should be set. This topic is sometimes a little complex, and I would suggest you reach out to support for confirmation as well.

 

maybe worth a read

• https://business.adobe.com/products/analytics/general-data-protection-regulation.html
• https://experienceleague.adobe.com/en/docs/analytics/admin/admin-tools/data-governance/data-labels/g...

[igupta]

Adobe Analytics as a system is generally considered third-party by organizations and when you are storing some sensitive information such as user ID on Adobe Analytics server, it's usually regarded as PII violation and is not encouraged. However, if you use data labelling as mentioned here, use data encryption coupled with appropriate approvals, you should be good to go.

Few other things I would like to add in addition to what @bjoern__koth has mentioned-

1. If you absolutely have to capture PII, it's best to encrypt it using some hashing technique. Most common one that is used is sha256.Now remember, SHA256 is one way hash. The only way to get original data is by hashing the data in other system such as CRM or database where all IDs are stored using same algorithm and then using the hashed data as key to get the original value. This way, you will not be violating GDPR and still have access to the reports client is looking to get insights/targeting enabled for.

2. You may want your client to obtain a Data Protection Officer approval to capture this data in Adobe Analytics.

Best,

Isha

[Amruthesh_AG]

@priyankagupta20Please confirm if userID is only a numbers? then you can add prefix logic add some character at starting of the userID or end of the userID

EX: 567890 

ABC567890  or 567890ABC