No more data collection frenzy: Google makes reCAPTCHA GDPR-compliant

For a long time, the use of Google's reCAPTCHA was a data protection tightrope walk for European website operators. The service is intended to protect against bots and spam. However, the type of data processing regularly caused headaches in legal departments. Until now, Google largely acted as an independent "data controller" when analyzing user behavior. This meant that the US company itself decided how and for what purposes the information collected in the background was processed – often with reference to the general Google data protection regulations. This era of non-bindingness is now coming to an end.

As Google has announced, a change of direction is imminent. As of April 2, 2026, the tech giant will globally change the operating model of reCAPTCHA. The service will transform from an offering with its own data sovereignty to classic order processing.

This integrates the bot protection into the ranks of professional Google Cloud Services and will in future follow the same compliance requirements that customers already know from the hyperscaler's cloud platform. The step goes beyond a formal adjustment of the terms and conditions: it shifts the power balance in data processing in favor of the operators.

Role reversal in data responsibility

In practice, the transformation means that from spring onwards, website operators themselves will step into the role of "Data Controller". They will determine the purpose and means of data processing, while Google will merely act as "Data Processor". Google will therefore only process the data collected on the customer websites according to strict instructions from the respective operators.

The company is thus responding to ongoing criticism from data protection advocates. They complained that user data from security queries could flow unnoticed into the advertising group's huge profiling pools. With the new structure, a clear dividing line is drawn: the collected information may henceforth only be used for the provision, maintenance, and security of the reCAPTCHA service itself.

The change will be particularly noticeable for users. Anyone who visits a website protected by reCAPTCHA will often still see a reference to Google's privacy policy and the company's terms of use in the small logo badge. These references will disappear from the effective date. Since users are no longer subject to the general Google terms and conditions, the direct legal link in the widget is omitted. Google proactively urges its customers to remove existing manual references to the Google Privacy Policy in connection with reCAPTCHA from their presences to comply with the new legal situation.

Seamless transition and legal clarity

Technically, the transition is expected to be largely seamless for admins. Google assures that there will be no interruptions in service. Existing site keys will remain valid. The functionality of security features such as Account Defense or SMS protection will also remain untouched. The strategic integration is interesting: since all Classic keys have already been migrated to the Cloud platform, processing will now uniformly take place within the framework of the so-called Cloud Data Processing Addendum. This addendum is intended to provide companies with the necessary legal certainty, as data processing is now limited to threat detection and fraud prevention for specific purposes.

The change comes at a critical time. In an era where AI is used not only for defense but also for creating increasingly sophisticated bots, the need for reliable verification tools is growing. Website operators can, in principle, argue in the future with significantly fewer concerns that the use of the tool serves to safeguard legitimate interests in accordance with the General Data Protection Regulation (GDPR). This is because the risk of violating user rights through uncontrolled tracking is, for the time being, off the table.

(des)