Law Firm Owners: Google’s New Ad Data Rules Create Potential Legal & Ethical Risk
Action required for any law firm running Google Ads or using Google Analytics on its website.
Last month, Google changed how it handles data between Google Analytics and Google Ads. Depending on your law firm’s settings in these tools, this change may affect your Google Ads campaigns and require an update to your website’s privacy policy.
Use our Partners’ Decision Brief to make the necessary business and ethical decisions, then forward your decisions and the summary below to those who manage your website and Google Ads campaigns, with appropriate instructions.
Six leadership decisions your firm needs to make before your marketing team can act — covering risk tolerance, jurisdiction, and Rule 1.6 confidentiality.
Why This Matters
Failing to act carries two risks:
If your website links visitor behavior to Google user profiles without disclosure, you may face state privacy law violations, FTC scrutiny for undisclosed data sharing, and potential bar ethics issues under Rule 1.6 if prospective client data is involved.
Overcorrecting by blocking all ad cookies will significantly reduce the effectiveness of your Google Ads campaigns, including conversion tracking and bidding optimization.
Instructions for Your Web/Ads Manager
- Check Google Signals. Log in to Google Analytics and confirm whether Google Signals is currently ON or OFF (Admin → Data Collection).
- If Google Signals is ON: No changes needed. Data behavior is unchanged.
- If Google Signals is OFF: Google Ads will now automatically use ad cookies for users who have consented. Review your Consent Mode (ad_storage) settings and confirm this aligns with your firm’s privacy practices.
- Update the website privacy policy. Add language stating that user activity on the site may be associated with their signed-in Google account and that they can manage or delete this data at myactivity.google.com.
- If you want to opt out of ad cookie tracking entirely: Set the Consent Mode ad_storage default to “denied.” Note: it is likely that this will reduce the effectiveness of Google Ads conversion tracking and campaign optimization.
- If updates will take time: Request Google’s 90-day grace period at the link in the original Google notice before proceeding with any changes.
