Microsoft Clarity GDPR: Compliance Strategies for 2025

Microsoft Clarity is a go-to analytics tool for marketers, developers, and UX professionals who need real-time insights into user behaviour, without the overhead cost. With features like heatmaps, session recordings, and rage-click detection, Clarity makes understanding website engagement easier than ever. However, as more businesses adopt this tool to optimise user experience, questions around Microsoft Clarity’s GDPR compliance are becoming increasingly important. If your business operates in the UK or EU—or targets users in those regions—you need to ensure your implementation complies with the General Data Protection Regulation (GDPR).

This guide explores whether Microsoft Clarity is GDPR-compliant. It explains the data Clarity collects, its privacy features, legal responsibilities under GDPR, and how you can configure Clarity responsibly and transparently.

Microsoft Clarity is a free behavioural analytics platform that enables website owners to understand how visitors interact with their site. It focuses on qualitative insights through:

• Session recordings that capture user navigation patterns
  
• Heatmaps that show where users click and scroll
  
• Frustration signals such as rage clicks or quick backs
  
• Real-time data without traffic limitations
  

Its simplicity and cost-effectiveness make it especially useful for startups and small to medium-sized businesses that want to enhance their website performance and user experience.

As per Clarity’s privacy statement, it does not require users to input names, emails or direct identifiers. However, it collects behavioural and technical data that can still be considered personal data under GDPR.

Categories of data Clarity processes:

• User interactions: Mouse movements, scrolling behaviour, click paths
  
• Session details: Entry and exit pages, time on site, navigation patterns
  
• Device data: Browser type, screen resolution, operating system
  
• Form fields: Input data (masked by default)
  
• Geolocation: Estimated from anonymised IP addresses
  

When this data can indirectly identify individuals, especially when combined with other datasets, it is subject to GDPR.

Clarity includes several privacy-forward features designed to help reduce exposure to personally identifiable information (PII).

These features help support GDPR compliance, but do not guarantee it. Site owners are responsible for how Clarity is implemented and disclosed to users.

Yes, Microsoft Clarity is designed to be GDPR-compliant, with Microsoft acting as the data controller. The platform includes built-in safeguards like IP anonymisation and data masking, and Microsoft supports GDPR principles such as data minimisation and transparency.

That said, full compliance still depends on how you use Clarity. You are responsible for obtaining valid user consent, especially for features like session recordings, before any tracking begins. Microsoft recommends using a consent management platform and offers a Consent API to support this.

In short, Clarity enables compliance, but you must implement it correctly to meet your legal obligations.

Yes. Microsoft Clarity collects data that is not essential for website functionality. Under GDPR, this means you must obtain explicit, opt-in consent before Clarity is activated.

Article Consent must be:

• Freely given: Without coercion or service restriction
  
• Specific and informed: With clear explanations about what data is being collected and why
  
• Granular: Separate from other types of processing (e.g. marketing)
  
• Revocable: Users must be able to withdraw consent easily
  

Enabling Clarity based on “legitimate interest” is risky and unlikely to hold up under scrutiny.

1. Use a consent management platform (CMP)

A GDPR-compliant CMP like CookieYes ensures Clarity scripts are blocked until the user gives consent. It should allow you to:

• Display banners to users in applicable regions (e.g. the EU or UK)
  
• Provide cookie category-specific toggles (e.g. “Analytics”)
  
• Record user consent logs and store them securely
  
• Offer an easy way for users to manage or withdraw cookie consent

Use callback-based loading to only fire the Clarity script once consent is confirmed.

2. Configure privacy settings within Clarity

Use Clarity’s settings to follow the principle of data minimisation.

• Choose balanced or strict masking modes
  
• Manually mask any additional sensitive fields
  
• Exclude internal traffic using IP blocking
  
• Disable tracking on sensitive pages (e.g. login, payment, dashboard)
  

Review your settings regularly to reflect site updates.

3. Update your privacy and cookie policies

Be transparent about your use of Microsoft Clarity in your privacy documentation. Include:

• The purpose of using Clarity (behavioural analytics)
  
• The categories of data collected
  
• Your legal basis (consent under Article 6(1)(a))
  
• The identity of the data processor (Microsoft Ireland Operations Ltd.)
  
• Where the data is stored (United States)
  
• Reference to the EU–US Data Privacy Framework
  
• A link to Microsoft’s privacy statement
  

In your cookie policy, name and describe the cookies used by Clarity, including their duration and purpose.

4. Enable users to change their consent anytime

GDPR requires that users be able to withdraw consent as easily as they gave it. You should:

• Provide a persistent “Cookie settings” link (typically in the footer)
  
• Ensure the CMP interface allows consent withdrawal
  
• Stop all Clarity tracking once consent is withdrawn
  

Consent controls must be accessible and functional.

5. Keep documentation up to date

Maintain internal GDPR records (Article 30) that describe:

• What Microsoft Clarity is used for
  
• The categories of data involved
  
• The legal basis (consent)
  
• How long data is retained (up to 13 months)
  
• What safeguards are in place
  
• Contact information for your data protection officer, if applicable
  

Regularly review these records and update them with any changes to your implementation.

6. Fulfil user data rights

Under GDPR, users have the right to:

• Access their data
  
• Request deletion or correction
  
• Object to or restrict processing
  

Because Clarity does not offer a user-facing dashboard, you must:

• Accept and log user requests
  
• Coordinate with Microsoft support if deletion is required
  
• Respond to requests within 30 days
  

Explain this process clearly in your privacy policy.

Microsoft Clarity data is stored in the United States. Under GDPR, international transfers require a legal safeguard.

Microsoft complies with the EU–US Data Privacy Framework (DPF), approved by the European Commission in July 2023. This allows the transfer of data to Microsoft’s U.S.-based servers under Article 45 of the GDPR.

What you should do:

• Mention the international data transfer in your privacy policy
  
• Reference the DPF adequacy decision
  
• Provide a link to Microsoft’s DPF certification and privacy policy
  

This provides the necessary transparency to stay compliant with GDPR requirements.

Clarity is a strong contender if you are looking for affordable, behaviour-focused analytics, but it requires careful handling to ensure GDPR compliance.

Microsoft Clarity offers advanced analytics capabilities with privacy features like IP anonymisation, masking, encryption, and data minimisation. But GDPR compliance is not automatic.

To use Microsoft Clarity lawfully, you must:

• Collect and manage opt-in consent
  
• Configure privacy settings responsibly
  
• Keep your documentation updated
  
• Handle international data transfers transparently
  
• Support users’ rights under GDPR
  

When set up correctly, Microsoft Clarity can be a compliant and powerful addition to your digital analytics toolkit, helping you optimise user experience while respecting data privacy.