The Digital Markets Act (DMA), also known as Regulation 2022/1925, was approved in 2023 and came into force in March 2024. DMA introduces various requirements to Google and other big companies, called gatekeepers, for serving ads in the EEA and the UK. Responsibility for collection and management of user consent is one of the requirements. Website users must give explicit Cookie Consent for tracking them. 

It is expected that these DPA requirements will result in big data losses, especially on the mobile side. To bypass this data loss, Google created the Google Consent Mode v2 and launched new consent management requirements for Consent Management Platforms (CMPs). Only Google-certified CMPs could use Google advertising products in the EEA or the UK.

If businesses want to use Google advertising products and get maximum results from marketing, they need to use Google Consent Mode v2, provided by a Google-certified CMP.

Google Consent Mode v2 has the maximum application with Google Analytics 4 (GA4), especially in terms of behavioral modeling. When you implement Google Consent Mode v2 and a consent banner for your website or app, GA4 will use Observed data or Modeled data for reporting user and session metrics. Behavioral modeling is applied to users who refuse analytics tracking and is based on the behavior of similar users who have accepted the tracking instead.

Read this blog to find out more about Google Consent Mode's behavioral modeling and how to get maximum results from marketing using Google.

CookieScript is a Google-certified CMP, integrated with Google Consent Mode v2, Google Tag Manager (GTM), and recommended by Google for serving ads in the EEU and the UK.
With CookieScript, you can use Google ads and Google Analytics 4 for serving ads and analyzing the results.

Observed Data Vs Modeled Data

There are two types of data, used by GA4: Observed data and Modeled data.

When users visit your website or app and grant consent for analytics cookies or when they don't opt out of personalization using advertising ID, Google Analytics associates user behavior with various identifiers to measure users’ activity. This data is called observed data and is the most reliable. Cookies, local storage, session storage, or other trackers could be used to collect observed data.

When users don't grant user consent, events are not associated with a persistent user identifier, so the data will be missing for these users. In this case, GA4 uses modeled data to extrapolate user behavior. To get modeled data, GA4 uses behavioral modeling to estimate and model the behavior of users who decline analytics cookies based on the behavior of similar users who accept analytics cookies.

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What Is the Behavioral Modeling of Google Consent Mode?

Behavioral modeling is a statistical technique that uses machine learning to predict the behavior of a user based on the behavior of similar users who accept analytics cookies or based on the users’ past actions.

Behavioral modeling gives businesses the ability to extrapolate meaningful insights from their user base even when they do not grant user consent to use their data for advertising purposes. As a result, you can use Google Ads or Google Analytics while maintaining compliance with the GDPR and other privacy laws around the world.

Behavioral modeling is used in the following Google products:

• Google Analytics 4
• Google Ads
• Floodlight
• Conversion Linker

How does Behavioral Modeling Work in GA4?

Behavioral modeling uses machine learning to estimate data based on user and session metrics when cookies or user_id are not available. When a user declines consent in GA4, their data is not stored in cookies or user IDs. However, GA4 still collects some information about these users, like their IP address, device type, and operating system. This information is used to train a machine learning model that predicts how the user would have behaved if they had consented to tracking.

GA4 uses analytics cookies to track users’ behavior. When a user accepts cookies, GA cookies are saved to the user's device.

Note, that if a user accepts cookies and then declines them, GA cookies remain after after declining. Google Consent Mode v2 works by setting cookies, but not storing info on their servers after the decline of cookies. This is necessary for GA4 to work correctly. Google Consent Mode v2 takes care of privacy regulations and don’t use user data. If you delete cookies, Google services like GA4 will not work properly.

Two versions of Google Consent Mode v2 could be used for your remarketing campaigns: basic Google Consent Mode or advanced Google Consent Mode. They differ in the amount of data collected, which influences the results of behavioral modeling. It is recommended to use advanced Google Consent Mode.

Google's behavioral modeling approach

Google's behavioral modeling approach applies the following machine learning best practices:

• Accuracy: GA4 uses Holdback validation to maintain data accuracy. It means, that the estimated data are compared with a part of the observed user data and used by the model to verify its validity and accuracy.
• Reliability: Behavioral modeling is only included when certain prerequisites are met. The most important factor for behavioral modeling is a sufficient number of users who granted consent. If there are not enough users, modeling is not triggered. These prerequisites are needed to ensure high confidence in model quality.
• Separation: Google uses separate modeling algorithms for the observed data to reflect your business and customer behavior.

What Is Conversion Modeling in Google Analytics?

Like behavioral modeling, conversion modeling extrapolates conversion trends from users who granted user consent to estimate conversion events for users who denied consent. Modeled conversions allow us to understand customers better and improve advertising campaigns while maintaining user privacy.

Conversion modeling of Google Consent Mode v2 is always activated- you can’t choose whether to use it or not. Reports that use conversion modeling aren’t distinguishable from those that don’t.

The Benefits of Behavioral Modeling

• Understanding of users. By incorporating behavioral modeling, organizations can gain a deeper understanding of their users and their actions even without the explicit consent of users.
• Data accuracy. Behavioral allows businesses to enhance the accuracy of their analytics data, compensating for missing information from users who did not grant consent.
• Compliance with data privacy regulations. The usage of behavioral allows businesses to collect and use user data while maintaining their users' privacy and complying with data privacy regulations.

The Limitations of Behavioral Modeling

• Not precise. The forecasts made by the model are not consistently precise.
• Approximation. The behavioral modeling can only be employed to approximate the information that would have been gathered from users who have refused consent.
• No new data. The behavioral modeling cannot be utilized to gather new data from users who have refused consent.
• Not real-time. The behavioral modeling does not report real-time reports events or real time data.
• Not predictive. The behavioral modeling does not provide predictive metrics- it could solely be used to interpret current customer behavior based on past events.

Prerequisites for Behavioral Modeling:

To use behavioral modeling in GA4 for your website or app, you need to have the following prerequisites:

1. Google Consent Mode v2 is enabled across all pages of your websites and all app screens of your apps.
2. Make sure that your Google Consent Mode is updated to v2.
3. Google Consent Mode v2 for web pages must be implemented so that tags are loaded before the consent dialog appears, and Google tags load in all cases, not only if the user consents (in the case of advanced implementation).
4. Your website or app collects at least 1000 events per day with analytics_storage='denied' for at least 7 days.
5. The property has at least 1000 daily users sending events with analytics_storage='granted' for at least 7 of the previous 28 days. When you have a few users, it may take more than 7 days to meet the data threshold within those 28 days to train the model successfully.

Conclusion

Behavioral modeling is a powerful tool that can help businesses collect data from users who have declined user consent. However, behavioral modeling has some limitations. Most importantly, there are certain prerequisites for behavior modeling: Google Consent Mode must be updated and enabled correctly, implemented in the right way, and at least 1000 events per day with analytics_storage='denied' and at least 1000 events per day with analytics_storage='granted' must be collected for at least 7 days.

CookieScript, a Google-certified CMP, integrated with Google Consent Mode v2, Google Tag Manager (GTM), and recommended by Google, is an optimal solution for your advertising campaigns in the EEU and the UK.

Read more about:

• What is Google Consent Mode v2?
• What is a Google-certified CMP?
• How to choose a Google-certified CMP partner for ad compliance?
• IAB TCF V2.
• Google’s guide on behavioral modeling for consent mode.

Frequently Asked Questions

What is the behavioral modeling of Google Consent Mode?

Behavioral modeling is a statistical technique that uses machine learning to predict the behavior of a user based on the behavior of similar users who accept analytics cookies or based on the users’ past actions. It allows extrapolating meaningful insights even when users do not grant user consent. To utilize behavioral modeling, you need to use Google Consent Mode v2. CookieScript is a Google-certified CMP, integrated with Google Consent Mode v2, Google Tag Manager (GTM), and recommended by Google for serving ads in the EEU and the UK.

How does behavioral modeling in Google Analytics work?

There are two types of data, used by GA4: Observed data and Modeled data. Behavioral modeling is applied to users who refuse analytics tracking and is based on the behavior of similar users who have accepted the tracking instead. Keep in mind that behavioral modeling has several prerequisites. For example, at least 1000 events per day with analytics_storage='denied' and at least 1000 events per day with analytics_storage='granted' must be collected for at least 7 days.

Does behavioral modeling comply with the GDPR?

Yes. Google Consent Mode v2 does not collect user data if users deny user consent. Instead, behavioral modeling is used to predict the behavior of a user based on the behavior of similar users who accept analytics cookies or based on the users’ past actions and extrapolate meaningful insights from their user base even when they do not grant user consent. Thus, behavioral modeling complies with the GDPR and other privacy regulations.

What does Google Consent Mode do during behavioral modeling?

When users deny user consent, Google Consent Mode v2 prevents Google Analytics from generating a user ID for that user. Instead, Google will record pings (events), that are not associated with the user. Google can then compare those pings to the actual behavior of similar consenting users using behavioral modeling to provide marketers with a more accurate look at site metrics while respecting user’s privacy preferences.