AnalyticsGoogle Tag Manager and the GDPR: agreement, role and data location.
Google Tag Manager is a analytics tool. Most customers use it as a processor, it explains how to get its data processing agreement, and the data location depends on your account. Below: what to check and how to declare it.
Prefilled for you · Free to set up · No credit card
In short
- Category
- Analytics
- Usual role
- Usually a processor
- Data location
- Set per account or project
- Agreement
- Obtained through the vendor
What does Google Tag Manager do with personal data?
Measure website or service usage and understand visitor interactions. That is how Privacyboard describes a typical use of Google Tag Manager, as a starting point you can edit.
The data usually involved: account identifiers, IP addresses, Website & device data, Usage & activity data
Is Google Tag Manager a processor or a controller?
Most customers use Google Tag Manager as a processor: it handles personal data on their instructions, for the purposes they set. That is the common reading for analytics tools and it is what Privacyboard suggests.
As a processor, it needs a written agreement with you under Article 28, and you should know which subprocessors it uses. Confirm the role against your own agreement, because the way you use a tool can change it.
Where does Google Tag Manager store personal data?
Google Tag Manager does not have one fixed location for every customer. The location depends on the plan, the account and the services you enable.
How to find yours: Look at the address you log in to or your project settings.
Even when the main location is in the EU, ask whether subprocessors or support access involve a transfer outside the EEA, and record it if so.
Which legal basis usually applies to Google Tag Manager?
For the usual use of Google Tag Manager, companies most often rely on consent (GDPR Article 6(1)). Analytics that read or write identifiers on the visitor’s device need consent, under the ePrivacy rules as well as the GDPR.
Some anonymous audience measurement tools can run without consent in France when the CNIL’s conditions are met (own purposes only, anonymous statistics, no cross-site tracking).
This is a starting point, not legal advice: the basis belongs to your activity, and you confirm it in your register.
Sources: CNIL: audience measurement tools exempt from consent, CNIL: cookies and other trackers, questions and answers
Does Google Tag Manager have a data processing agreement?
Checked on 5 November 2026. Vendors change their pages, so check the date.
Google Tag Manager does not publish the full text of its data processing agreement on a public page. The reference page explains how a customer gets or signs it, usually from inside the account. Article 28 of the GDPR still requires a written contract, so get it and keep a copy.
What we noted when we opened the page: Google help page explaining that the Google Ads Data Processing Terms apply to Tag Manager and are accepted in Admin > Account Settings (pre-accepted for EEA/UK/Swiss sign-ups). No hosting location or transfer tool stated on the page.
A page that exists does not mean you are covered. Whether the agreement applies to you depends on your plan and on what you accepted, so record the decision yourself in your vendor list.
Open the Google Tag Manager reference pageHow to declare Google Tag Manager
- 1
In your privacy policy
Name Google Tag Manager as a recipient, say what it is used for (measure website or service usage and understand visitor interactions) and mention any transfer outside the EEA. Articles 13 and 14 ask you to tell people who receives their data.
- 2
In your vendor list
Add Google Tag Manager with its purpose, the data involved, its role, its region and a link to the agreement. Privacyboard prefills all of this, you confirm or correct it.
- 3
In your processing register
Link Google Tag Manager to the activities that use it, so each record shows its recipients. Article 30 asks the register to list the categories of recipients.
What to check before relying on Google Tag Manager
- Check whether the tool sets cookies or reads device data, and what consent that requires.
- Say in your privacy policy what is measured and for how long it is kept.
- Review IP address handling, data retention and the data region settings.
- Confirm whether the provider uses the data for its own purposes.
Go online for free. Grow when you need to.
Free puts you online. Pro adds requests, domains and your team; Business, your brand only.
Free
$0 forever
No card, no time limit
For getting compliant and going online on your own.
Start for freeKey features:
- Privacy and cookie policies
- Vendor and processing registers
- Requests and breaches tracked
- Impact assessment screening
- Privacy center on privacyboard.io
- Cookie banner on 1 domain
- 1 person
No card needed
ProRecommended
$32 per month
Billed $384 a year Save $84
For taking requests, covering all your sites and working as a team.
Start with ProEverything in Free, plus:
- DPA for your clients
- PDF and Excel exports
- Email reminders
- Request form and replies
- Your own domain
- Banner on 3 domains, every choice logged
- Weekly site scan
- Complete DPIAs and TIAs
- AI assistant connector
- Up to 5 people, with roles
Cancel any time
Business
$109 per month
Billed $1,308 a year Save $240
For proving it to customers and auditors, under your brand only.
Start with BusinessEverything in Pro, plus:
- No Privacyboard mention
- Security section and vendor alerts
- Evidence pack in one click
- Banner on 10 domains, daily scan
- Up to 50 people
- Two-step verification required
- Activity log kept 3 years
Bank transfer on request
Questions, answered.
Is Google Tag Manager GDPR compliant?
Privacyboard does not certify vendors. Compliance depends on how Google Tag Manager is configured and used, on the agreement you have with it and on your own practices. What can be checked is documented here: it explains how to get a data processing agreement, the usual role and the data location. Read the agreement itself before relying on it.
Does Google Tag Manager have a DPA?
Google Tag Manager does not publish the full text of its data processing agreement on a public page. The reference page explains how a customer gets or signs it, usually from inside the account. Article 28 of the GDPR still requires a written contract, so get it and keep a copy. The reference page is https://support.google.com/tagmanager/answer/7207086.
Is Google Tag Manager a data processor?
Usually, yes. Most customers use Google Tag Manager as a processor that acts on their instructions. Check your own agreement and how you use the tool, because the role can differ.
Which legal basis applies when I use Google Tag Manager?
For the usual use of Google Tag Manager, companies most often rely on consent (GDPR Article 6(1)). Analytics that read or write identifiers on the visitor’s device need consent, under the ePrivacy rules as well as the GDPR. Some anonymous audience measurement tools can run without consent in France when the CNIL’s conditions are met (own purposes only, anonymous statistics, no cross-site tracking).
Where does Google Tag Manager store data?
Google Tag Manager does not have one fixed location for every customer. The location depends on the plan, the account and the services you enable. How to find yours: Look at the address you log in to or your project settings.
Do I need to mention Google Tag Manager in my privacy policy?
Yes, if Google Tag Manager handles personal data for you. The GDPR asks you to tell people who receives their data (Articles 13 and 14). Name the vendor or its category, say what it is used for and mention any transfer outside the EEA.
How do I add Google Tag Manager to my vendor list?
In Privacyboard, pick Google Tag Manager from the catalog. The purpose, the data, the suggested role and a link to its agreement are prefilled, and you confirm each one. Creating a workspace is free.
Similar tools
Privacyboard is not affiliated with Google Tag Manager. Names and logos belong to their owners and are used only to identify the tool. This page summarises public documents as checked on 1 November 2026; it is guidance, not legal advice, and it does not certify any vendor.