Consent requirements for the European Economic Area (EEA)

This document describes Ads Data Hub product and policy changes related to EEA user consent requirements. It is intended for all users of Ads Data Hub.

What's changing?

Beginning January 16, 2024, Google will update Ads Data Hub to include:

  • A new attestation to indicate that you have obtained consent for data uploaded into Ads Data Hub
  • New policy-isolated tables that split data out by Google services, and
  • Updated templates to help you write queries that comply with our EU user consent policy

Why is Google making these changes?

As a part of Google's ongoing commitment to a privacy-centric digital advertising ecosystem, we are strengthening the enforcement of our EU user consent policy.

What do I need to do?

All customers:

  • Beginning January 16, 2024, all Ads Data Hub customers, irrespective of region, will need to attest that appropriate consent has been obtained pursuant to the Ads Data Hub policies, complying with the EU user consent policy and the Ads Data Hub policies, where applicable, for any first-party data uploaded to Ads Data Hub by March 2024.
  • Failure to do so could impact ability to use advanced measurement, ad personalization, and remarketing features.

Customers with EEA data:

  • Beginning January 16, 2024, all EEA data will be split by Google service into new policy-isolated tables.
  • Beginning March 2024, queries that do not use the policy-isolated tables will no longer return EEA traffic, and you won't be able to combine EEA data between Google services tables or across non-EEA and EEA tables.

To learn more about these changes, and what actions you should take, read the following sections.

Learn key terms

Google service: A product or a service, such as online advertising services, online search engines, and video-sharing platform services. Examples of Google services are Ads, Search, and YouTube. Learn more about Google services.

European Economic Area (EEA): The European Economic Area consists of the member states of the European Union (EU) and three countries of the European Free Trade Association (EFTA)—Iceland, Liechtenstein and Norway.

First-party data (1PD): First-party data is information you collected from your websites, apps, physical stores, or other situations where customers shared their information directly with you. To learn more, see Customer data in the Policies page.

Understand important dates

January 16, 2024 Product changes begin to go into effect.

March 2024 Product changes go into full effect.

  • All customers, irrespective of region, must attest that appropriate consent has been obtained, complying with the EU user consent policy where applicable, for any personal data uploaded to Ads Data Hub. Failure to acknowledge consent or refusing consent acknowledgment results in the inability to use your first-party data (1PD) within Ads Data Hub. For example, you cannot bring in new 1PD or join existing 1PD with your linked ads data. All use cases, such as user-provided data matching and audience activation using 1PD, are unavailable. This includes any scheduled 1PD imports.
  • Ads Data Hub will stop dual-writing EEA data, using only the per-service tables going forward. See the section called Schema changes.
    • Saved queries using the old tables will no longer represent EEA traffic. Existing queries using the tables will continue to measure any non-EEA traffic.
    • For any EEA data, you won't be able to join between Google Services tables, such as Ads and YouTube.
    • You won't be able to join non-EEA tables with EEA tables.

To ensure you are able to use your first-party data in Ads Data Hub, you must confirm that you have obtained proper consent to share data from EEA end users with Google per the EU user consent policy and Ads Data Hub policy. This requirement applies to each Ads Data Hub account, and must be updated every time you upload new first-party data. Any one user can make this acknowledgement on behalf of the entire account.

To acknowledge consent from the consent warning banner or the first-party data consent dialog:

  1. Click Configure consent settings.
  2. In the slider that opens, click Yes, consent has been obtained.

To acknowledge consent manually or from a query validation warning:

  1. In your Ads Data Hub account, go to the Settings page.
  2. Under First-party data use consent settings, click Configure consent settings.
  3. In the slider that opens, click Yes, consent has been obtained.

To view a record of consent acknowledgment changes:

  1. In your Ads Data Hub account, go to the Settings page.
  2. Click Change history.
  3. Filter by type: Customer settings change.

Schema changes

Starting January 16, 2024, Ads Data Hub will dual-write EEA data in both the non-isolated tables and the policy-isolated tables.

  • Saved queries using the non-isolated tables will continue to represent EEA and non-EEA traffic.
  • You can begin to use the policy-isolated tables. To learn how to migrate your queries, see Update impacted queries.
  • You won't be able to combine data between any of the policy-isolated tables.
  • You won't be able to combine the non-isolated tables with the policy-isolated tables.

Schema changes for Marketers

EEA user data is split by Google service into policy-isolated tables. Non-EEA users remain in the non-isolated tables.

The following example uses the Google Ads impressions table to show how a table is split by Google service:

Before March 2024 Beginning March 2024
Users Google service Table Users Google service Table
Non-EEA users
EEA users		 YouTube
Gmail
Network		 google_ads_impressions Non-EEA users YouTube
Gmail
Network		 google_ads_impressions
EEA users YouTube google_ads_impressions_policy_isolated_youtube
Gmail google_ads_impressions_policy_isolated_gmail
Network google_ads_impressions_policy_isolated_network

Schema changes for Measurement Partners

All user data is split by Google service into policy-isolated tables.

The following example uses the Google Ads impressions table to show how a table is split by Google service:

Before March 2024 Beginning March 2024
Users Google service Table Users Google service Table
Non-EEA users
EEA users		 YouTube
Networks		 google_ads_impressions Non-EEA users
EEA users		 YouTube google_ads_impressions_youtube
Network google_ads_impressions_network

Update impacted queries

To prevent interruption in reporting, you can update your queries to use the policy-isolated tables before enforcement is in effect. The following example demonstrates how to rewrite queries to be compliant with the consent requirement policy.

Consider the following example query, which counts YouTube impressions by platform. Before March 2024, all YouTube impressions for EEA and non-EEA users are grouped together in the google_ads_impressions table.

SELECT
  CASE
    WHEN mobile_browser_class = 3 THEN 'DESKTOP'
    WHEN mobile_browser_class = 2 THEN 'MOBILE'
    WHEN mobile_browser_class = 4 THEN 'TABLET'
    WHEN mobile_browser_class IN (5, 6, 7) THEN 'CONNECTED_TV'
    ELSE 'UNKNOWN'
    END AS platform,
  COUNT(*) AS num_imp,
  COUNT(DISTINCT user_id) AS num_cookie
FROM adh.google_ads_impressions
WHERE customer_id IN UNNEST(@customer_ids)
  AND inventory_type = 'YOUTUBE'
GROUP BY platform

If you don't have any data from EEA users, you don't need to change your query. It will continue to return non-EEA results. However, if your data represents any EEA users, you will need to update or create an additional query to find EEA impressions after March 2024.

By replacing the table with google_ads_impressions_policy_isolated_youtube, the following query counts YouTube impressions for EEA end users only. Note that when you use this table, it is no longer necessary to filter by inventory type, so that line can be omitted from the WHERE clause.

SELECT
  CASE
     WHEN mobile_browser_class = 3 THEN 'DESKTOP'
     WHEN mobile_browser_class = 2 THEN 'MOBILE'
     WHEN mobile_browser_class = 4 THEN 'TABLET'
     WHEN mobile_browser_class IN (5, 6, 7) THEN 'CONNECTED_TV'
     ELSE 'UNKNOWN'
     END AS platform,
  COUNT(*) AS num_imp,
  COUNT(DISTINCT user_id) AS num_cookie
FROM adh.google_ads_impressions_policy_isolated_youtube
WHERE customer_id IN UNNEST(@customer_ids)
GROUP BY platform

Unsupported use cases

Don't: Combine EEA data with non-EEA data

Applies to: Marketers

Queries that combine EEA data with non-EEA data show an error message in the query editor and fail to run. For example a query combining the Google Ads impressions table (containing non-EEA user data) with the Google Ads YouTube impressions table (containing EEA user data) is not allowed, and fails with an error.

-- This query results in an error
SELECT
  COUNT(*) AS num_imp,
  COUNT(DISTINCT user_id) AS num_cookie
# Non-EEA table
FROM adh.google_ads_impressions
  AND inventory_type = 'YOUTUBE'
UNION ALL
SELECT
  COUNT(*) AS num_imp,
  COUNT(DISTINCT user_id) AS num_cookie
# EEA table
FROM adh.google_ads_impressions_policy_isolated_youtube

To clear the error, query the policy-isolated table separately. See Update impacted queries.

Don't: Combine EEA data across multiple Google services

Applies to: Marketers, Measurement Partners

Queries that combine the policy-isolated tables from different Google services show an error message in the query editor and fail to run. For example, a query joining EEA Google Ads Gmail data with EEA Google Ads YouTube data is not allowed, and fails with an error.

Note that you may combine policy-isolated tables from the same Google service across buying doors.

Do: dv360_youtube_impressions_policy_isolated_youtube + google_ads_impressions_policy_isolated_youtube

Do: google_ads_impressions_youtube + google_ads_conversions_youtube

Don't: google_ads_impressions_policy_isolated_youtube + google_ads_impressions_policy_isolated_gmail

To learn more about impacts specific to Measurement Partners, see Inventory split migration guide.