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Explore the best practices for using Google Tag Manager's `dataLayer` when handling personal information (PII). Learn about the implications, risks, and considerations for managing user data securely and legally.
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Understanding dataLayer Restrictions in Google Tag Manager: Should You Send PII?

In the ever-evolving landscape of data privacy, many webmasters and marketers find themselves grappling with how to handle user information responsibly. A frequently asked question in this regard is whether it is safe to send Personally Identifiable Information (PII), such as email addresses or names, through the dataLayer.push() method in Google Tag Manager (GTM). This guide will dive deep into the intricate relationship between data handling and privacy laws to provide clarity on this pressing issue.

The Core Question

As you consider using dataLayer.push() to transport user information like email addresses, it's crucial to assess both the potential risks and the legal framework governing data usage. While at first glance, it may seem harmless to store user data in the dataLayer, a deeper look is warranted. Here are some common considerations:

What does dataLayer.push() do?
It's essential to understand that dataLayer.push() itself merely stores the pushed data into a variable that's made available locally within the user's browser. It does not inherently transmit this data anywhere else.

What are the implications of storage?
While the act of storing data in the dataLayer may not pose immediate risks, the critical questions are centered around how that data will be utilized thereafter and what privacy laws may apply in your region.

Privacy Laws and Best Practices

1. Jurisdiction Matters

Data privacy laws vary significantly across different regions. For instance:

General Data Protection Regulation (GDPR): If you're operating in Europe, any handling of user data must comply with the GDPR, which imposes stringent rules regarding user consent and data processing.

Other Laws: Various countries may have their own privacy norms that could affect how you manage user data.

2. Tracking Tools Terms of Service

Users must understand the Terms of Service (TOS) of the tracking tools employed. For instance, Google Analytics explicitly prohibits the sending of PII, regardless of whether local laws permit it.

3. User Consent is Crucial

The best practice when dealing with sensitive information is to ensure that you have clear and explicit consent from users before storing or processing their data. If users have opted in and you require their email for service delivery, you might safely push that data into dataLayer for essential functionality.

Understanding the Risks

Accessibility

One important aspect to consider is that once data is stored in a variable, it can potentially be accessed by all other tracking tools implemented on your webpage. This poses two significant points to consider:

Widespread Access: Multiple tools could potentially read data that had been stored, which could lead to unintended data exposure.

Existing Vulnerabilities: Keep in mind that savvy users can also read from input fields or other elements on the page description, which doesn’t significantly add to risk but warrants caution nevertheless.

Final Thoughts

In conclusion, while using dataLayer.push() to send email addresses or other PII isn't necessarily harmful in isolation, it invariably leads to a host of questions around legality, appropriateness, and overall best practices for data handling. Always prioritize user consent, stay informed about privacy legislation in your jurisdiction, and adhere strictly to your tracking tools' TOS to operate within safe and responsible boundaries.

For a definitive answer tailored specifically to your situation, consulting with a legal professional (especially regarding data privacy laws) is always recommended.

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