Mass mailings and German law conformity – provide do-not-track for civimail (opt-out from track open)

Question

German privacy acts demand fulfilling three requirements when sending mass mailings using tracking technology and I wonder how to achieve this. Because I think CiviMail's and CiviCRM's core and therefor all german users would benefit from a generic solution, I'd prefer handling this in civi itself. But walking the customization way is an option too.

1. Pseudonymization

   The tracking information has to be detached from all data which may identify the corresponding contact.

   AFAIK civi does not provide such a possibility or does it?

   How could we hook into database and reports to cut the link between tracking information and the civi contact? If the link is just a civicrm_contact_id in a tracking table, could we create a pseudonymic fake contact and generally override the db field with it's id?

2. Ability to contradict

   The possibility to opt-out from tracking is mandatory.

   How to implement a new communcation setting named somethin like "Do-not-track" besides "User opt-out" which tells the system to not insert tracking links or beacons in a contact's mails?

   Or – as a customization approach – should we add a custom field, edit it in the mails via a link to a custom extension's function and read it using some thing like hook_civicrm_alterMailContent?

3. Transparency

   Users have to be informed about all tracking that is done. Easy as it is a just a matter of text. But maybe we could add a default snippet.

Any help appreciated.

Answer 1

I don't think there is a way to achieve "pseudonymization" without having to touch code (except for turning off tracking altogether). However, implementing what you suggested, i.e. assigning the tracking events to a predefined contact ("Anonymous") one way or another, should be reasonably easy for a developer.

Adding on do-not-track flag is a different story though, that entails a lot of little changes throughout the system. It also raises questions like "if I set this flag for a contact, do we want to keep the previously gathered data?" or "should that flag also affect bounce processing?".

You might also consider doing this as an extension at first, because it will take a while to be released in an official CiviCRM version. Plus, you could make sure it's working and well thought-out.

Answer 2

Easiest would be to not track via CiviCRM. But track via Piwik (www.piwik.org).

You would get info about how much people visit your site from the Mailing (via https://piwik.org/docs/tracking-campaigns/#tracking-campaigns-using-url-parameters), but you would not see how much people opened the mail or who clicks which link.

Piwik has all the opt-out options you need.