What has changed and why?
In the light of updated guidance from the Information Commissioner's Office (ICO), the Government Digital Service (GDS) have reviewed the cookie policy for GOV.UK. The ICO have been taking a more robust interpretation of Privacy and Electronic Communications Regulations (PECR). These regulations say that
"You must tell people if you set cookies, and clearly explain what the cookies do and why. You must also get the user’s consent. Consent must be actively and clearly given."
Changes have been made to the cookie consent model to remain compliant with the newest guidelines. GDS has adopted an explicit informed consent (or 'opt-in') mechanism. This change was implemented on the 20th December 2019. As a consequence of this action, Google analytics will only capture activity from users that have opted-in to the use of analytics cookies. As a result, there has been an inevitable impact on central GOV.UK platform analytics.
From others’ experience, we were expecting to lose up to 80% of past data volumes, at least initially. If you use Google Analytics, or any dashboards to view user interactions, you may see that page views and user numbers have dropped significantly.
How big the actual drop will be in the longer term and how representative the new activity will be compared to all users are questions that as yet GDS are unable to answer. Work began at Government Secure Intranet (GSI) and other government departments to begin to understand the data that is still being collected. However, the current situation with COVID-19 has stalled this work for the time being.
So what can we do to understand and communicate the data we have?
The first thing to say is that the data has never been complete - issues with Javascript, Google sign-in and the previous cookie 'opt-out' model (think of all those "not set" countries and cities and "not provided" keywords)
So how do we communicate these changes:
- Explain why the data is not complete
- Round and bucket results. Forget decimal places, round things to the nearest 10 / 100/ 1,000 as appropriate to emphasise that these figures are not precise.
- Offer trends instead
- Use terms that communicate uncertainty - 'based on the data available', or 'approximately', to show that the figures aren't exact.
Update December 2020
Many government departments are working to overcome the challenges that cookies and consent present to the analytics community and our stakeholders.
For a more joined-up approach it is planed that Cookie Banner and Consent will be made consistent across GOV.UK domains.