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FluentCRM

#Feature Request

CNIL compliance: managing consent for email open and link tracking

Hello :)

The French Data Protection Authority (CNIL) recently published its final recommendation regarding tracking pixels and tracked links in emails. (As Italy by the way)

According to this recommendation, consent to receive marketing emails does not automatically constitute consent to the individual tracking of email opens and link clicks, particularly when this data is used for profiling, segmentation or marketing automations.

I currently use FluentCRM together with Fluent Forms, and I need to adapt my setup to comply with these requirements.

Could you please explain how this should be managed within FluentCRM?

More specifically:

  1. Can I store a contact’s consent to email tracking separately from their subscription status?
  2. Can FluentCRM dynamically disable both the open-tracking pixel and link tracking for contacts who have not consented, while still sending them the email normally?
  3. Can contacts withdraw only their consent to tracking without unsubscribing from the mailing list?
  4. Does FluentCRM keep sufficient proof of this consent and its withdrawal, including the date and source of the consent?
  5. How should automations based on email opens or link clicks behave for contacts who have not consented to tracking?
  6. Is there a recommended procedure for managing existing subscribers and collecting or recording their tracking preferences?

If these features are not currently available natively, could you please let me know whether there is a recommended workaround or whether support for consent-based tracking is planned?

Here is the CNIL recommendation for reference:
https://www.cnil.fr/fr/recommandation-pixel-suivi-courriels

Thank you for your help.

  • 4 comments

Karl Emil Nikka
  1. No. WPManageNinja recommends using FluentForms Pro for detailed subscription info (it’s necessary anyways since FluentCRM doesn’t offer double opt-in for unauthenticated, existing contacts).
  2. No, you need to create separate campaigns. You can use tags to select which contacts should be part of which campaigns.
  3. No.
  4. No.
  5. I haven’t looked into it.
  6. Not that I know of. The easiest way going forward is to just disable regular tracking and instead rely on anonymous tracking, introduced in FluentCRM 3.0.

WPManageNinja has confirmed that do not intend to fix the double opt-in compliance issue, but I haven’t asked about the other issues you bring up. They are worth submitting as feature requests. WPManangeNinja has addressed all compliance issues I’ve reported except for the mentioned double opt-in issue.  

David Churchill

Agree with Karl Emil Nikka, you would need to use a custom form for registration to collect consent, FluentForms Pro can do this and integrate with FluentCRM. Worth also checking how your email service works, if you use something like Brevo.com, they also add link tracking in emails unless you turn it off. toSend.com currently don't track clicks.

Claire Négrier

Thank guys ! I have FF Pro! So I'm gonna investigate on that - or if you have any lead to follow, I'm all ears! :D

Karl Emil Nikka

Claire Négrier If you receive an official answer through email or support ticket, please share it with us.