Facebook’s New Limited Data Use Tool Requires Immediate Action from Auto Marketers
Facebook has made data privacy-related changes to several of its APIs (including Offline Events and the Facebook Pixel) — and automotive marketers need to take immediate action in order to achieve successful retargeting and reporting.
July 1, 2020, began like any other day for the 9 Clouds team.
After logging on, a few of us got to work importing our automotive clients’ leads and sales from the past 15 days into their respective Facebook Offline Events sets to help them prove return on investment from Facebook ads.
That’s when our usual, streamlined process of importing Offline Events hit a full stop, thanks to a brand-new error message that had arrived sneakily overnight:
This row will not be uploaded to the server because the following fields are missing or invalid: Data Processing Options.
We were given no heads-up about this update. Why had a tool that had been working so smoothly for years suddenly changed with no notice?
Within a few minutes of digging, we found an answer in Facebook Developer documentation:
[Facebook] released a Limited Data Use feature to give businesses more control over how their data is used in our systems and better support them with their California Consumer Privacy Act (CCPA) compliance efforts.
Let’s break down what this means for your dealership.
Facebook Introduces the Limited Data Use Feature
Released on July 1, the Limited Data Use (LDU) feature enables businesses to choose whether or not to apply restrictions from Facebook Business Tools data from California.
Advertisers can implement Limited Data Use to specify when Facebook should process data in accordance with its role as a service provider under the CCPA.
According to Facebook’s state-specific terms, Facebook will now apply Limited Data Use to all personal information from people in California shared through Facebook products, including:
- Facebook Pixel
- Server-Side API
- App Events API
- Offline Conversions
Cut the Jargon. What Do I Need To Do?
In order to utilize these Facebook products, including the Pixel and Offline Events, you must tell Facebook whether or not to process your data by implementing the Limited Data Use flag.
This flag basically says, “Hey, Facebook, this is protected data, so don’t process it.”
All Facebook advertisers must take some sort of action — not just those with California-based customers.
If you want Facebook to process the data — either because the data does not belong to California users or because you’re willing to take on the liability of not complying with the CCPA — simply don’t flag your Offline Events and Pixel with the LDU flag.
Here is where we say that we are not lawyers, and this is not legal advice. Please consult legal advice in regard to compliance measures for your situation.
How to Handle Limited Data Use for Offline Events
Before you upload Offline Events, add a column to your spreadsheet called “Data Processing Options.” Indicate how Facebook should handle the data accordingly:
- Regular tracking (non-California): 
- Limited Data Use (California): [“LDU”]
The empty array explicitly specifies that the event can be processed normally.
Through our own trial and error at 9 Clouds, we’ve found that the [“LDU”] flag is essentially a kill switch.
So, if your dealership or business chooses to implement Limited Data Use across the board, there’s probably no need for you to spend time importing Offline Events at all.
If you are planning to implement Limited Data Use for California users but not for all data, you could either flag those contacts with LDU or simply not include them in your Offline Events import.
How to Handle Limited Data Use for the Facebook Pixel
The Pixel process works similarly to Offline Events.
With the Limited Data Processing feature comes a piece of code that must be added to all Facebook Pixels to indicate whether or not Facebook can actually process the Pixel’s tracking data. You have one of three options.
1. Regular Tracking (Non-California)
This option will disable limited data processing, so Facebook will process all data. By enabling this, however, you assume all liability and responsibility for the data processing Facebook is doing on your behalf.
Here’s what this line of code might look like in your Facebook Pixel code:
2. Limited Data Use (California)
This option will disable Facebook from processing any data from your Pixel.
Do be aware that if you have implemented Limited Data Use on your Facebook Pixel, your business will be unable to retarget your website visitors.
3. Limited Data Processing Based on the User’s Location
fbq(‘dataProcessingOptions’, [“LDU”], 0, 0);
With this option, a user who is in California would not be registered or processed by the Pixel, but a user in South Dakota would. This is a pretty safe setting to use, giving up some data processing in order to remain in compliance.
Is There a Grace Period to Figure It Out?
As of July 1, the Limited Data Use feature has been automatically enabled for all advertisers.
However, advertisers can opt out until August 1, 2020, in order to take time to update their processes and figure it out.*
To opt out of the Limited Data Use tool during the grace period, navigate to your Facebook Pixel settings and toggle this switch:
After July 31, this feature will be dismissed, and Facebook will require all businesses to be responsible for maintaining CCPA compliance by use of the LDU flag.*
*Update: As of September 1, Facebook is allowing you to extended the transition period to October 20.
How Will This Impact My Dealership?
Ultimately, what Facebook has done here is wiped its hands of any liability in regards to processing user data under CCPA. Now, it’s up to the advertiser.
If you’re an auto dealer in or near California, you don’t have to implement the Limited Data Use flag. Just know that with these updates, your business — not Facebook — is liable under the California Consumer Privacy Act.
A Time-Saving Data Formatting Solution
Listen, we know that formatting your automotive CRM data for Facebook Offline Events or Custom Audiences was already time consuming before this LDU tool rolled out.
You may be thinking, “Now I have to manually add even more data points?! It’s not worth my time to import offline sales and leads!”
Don’t throw in the towel yet. There is a solution.
With Hydra, our custom-built data formatting tool, auto dealers no longer need to waste hours combing through data and reformatting it to Facebook’s liking.
With a simple drag and drop, your CRM lists can be Facebook ready in seconds — Data Processing Options compliant and all!
Sound like a dream? It’s not. It’s real — and we’ve recently made it available to all.
Learn more about the tool and how it can make your life easier, especially amid these complicated Facebook LDU updates.tell me more about hydra