An open-tracking pixel is easy to overlook. It sits inside an email, loads when the recipient’s mail client displays images, and can tell the sender that a particular message was opened. For years, that was simply how many email reports worked. The Italian data protection authority, the Garante per la protezione dei dati personali, has now published guidance devoted to tracking pixels in email.
The guidance is dated 17 April 2026 and was published in the Gazzetta Ufficiale on 29 April. It calls attention to what recipients are told, how their choices are recorded and how they can withdraw from tracking while continuing to receive email. It provides a six-month period from publication for affected operators to adapt. The document itself is the source to read for its scope and requirements.
For senders using Interspire Email Marketer, this raises a practical product question: what information do you actually need from each email? Version 8.8.0 gives you more than an open-tracking checkbox with which to answer it.
The Garante’s document distinguishes campaign-wide statistical counting from measurement that follows an individual recipient. It also describes a recipient’s ability to stop tracking while still receiving messages. Those distinctions help an administrator understand the controls available in IEM.
Interspire provides tools to control email tracking. It makes no representation that any configuration satisfies the Italian guidelines, GDPR, ePrivacy, or any other law. The instance owner is the data controller and is responsible for enabling and configuring these controls, for the disclosure text shown to recipients, and for obtaining their own legal advice.
How the modes relate to the Garante guidance
The Garante’s guidance discusses campaign-wide statistical counts, individual measurement, information given to recipients and the ability to stop tracking without stopping email. Here is what each IEM mode actually does alongside those topics. This is a product comparison, not a judgment about which mode to use for a particular mailing.
| IEM mode | What IEM does | Topic in the Garante guidance |
|---|---|---|
| Off | Adds no open pixel and does not rewrite links for click tracking. | No IEM tracking pixel is included. |
| Minimal (date only) | Uses a recipient-specific pixel to keep one day-level last-open date per contact, with no open history or click events. | The guidance’s example of anonymous campaign-wide counting uses the same pixel for every recipient. Minimal does not work that way and is most likely not compatible with the Garante’s guidance. |
| Aggregate (anonymous) | Uses the same pixel for everyone in a campaign and keeps campaign totals, not individual open records. | The guidance describes a common campaign pixel and anonymous campaign-wide counting. |
| Individual (consented) | Records recipient-level opens and clicks only when IEM’s recorded tracking choices authorise them. | The guidance discusses informing recipients, recording their choice and allowing withdrawal of tracking while email continues. |
| Individual | Records recipient-level opens and clicks without consulting IEM’s consent records. | The guidance discusses individual measurement and recipient choice. This mode does not check that choice in IEM. |
These modes produce different kinds of answers. Aggregate can tell you how many opens a campaign received, but not which subscriber opened it or how many distinct people did. Minimal can tell you whether a contact has ever opened an email, but not how a particular campaign performed. The Individual modes retain the detail needed for per-contact reports and behaviour-based segments.
Do not use Minimal as a substitute for the anonymous campaign-wide counting described by the Garante. It still identifies each recipient to update that person’s last-open date. Aggregate uses the same pixel for every recipient in a campaign and keeps no per-recipient activity record. This distinction describes the data each mode collects; it is not a determination about the rules applicable to a particular mailing.
For a full comparison, including the reports available in each mode, see Email Tracking Modes Explained. The France/CNIL operator guide covers the separate French recommendation.
Let recipients change tracking without leaving the list
Stopping email and stopping tracking are different choices. A recipient may want the newsletter but not the record of their opens and clicks. IEM 8.8.0 provides a tracking preference page through the %%trackingpreferencelink%% merge tag, so the recipient can change tracking preferences without unsubscribing.
For lists using Individual (consented), subscribe forms can display tracking controls using disclosure text the instance owner provides. IEM stores each decision in a consent log with the actor and time. A recipient’s stop-tracking choice applies across that person’s lists belonging to the same list owner. IEM deletes their existing open and click history when storage-based tracking is withdrawn.
The withdrawal also reaches mail already delivered. A message in someone’s inbox can still contain a tracking URL after that person changes their preference. URL expiration does not solve that timing problem: a link can remain valid for some time after the recipient opts out. IEM checks the current choice when an open or click arrives and refuses to record the event after withdrawal. A click still reaches its destination; the tracking write does not happen.
That distinction matters because deleting an event later is different from never recording it. IEM attempts to remove existing history when the preference changes and uses the scheduled cleanup task as a backstop if that deletion fails. The receiving side blocks new events independently of that schedule.
Understand what the upgrade leaves in place
IEM does not switch an existing installation to a new tracking policy during the upgrade. Existing campaigns, autoresponders, triggers and lists keep the behaviour they had before, and the account default remains Individual. This preserves existing reporting until the operator reviews the new settings.
There is also a decision for contacts who were on a list before IEM recorded a tracking preference for them. In Individual (consented), the Off legacy policy leaves those contacts untracked until they choose to allow tracking. The Transitional policy keeps tracking them and adds a notice with a stop-tracking link. IEM does not put an expiry date on Transitional or change it automatically. Review that setting deliberately if you use it for an existing list.
You can also set a retention window for historical tracking events. At the end of the window, IEM can delete aged opens and clicks or reduce older opens to one day-level last-opened date. The scheduled task is seeded to run daily. It handles that optional retention window and retries a withdrawal purge if the immediate deletion did not finish. Disabling the task stops both scheduled functions; it does not turn future tracking back on for a withdrawn recipient.
What to review in IEM
Start at Settings → Email settings → Email tracking defaults. Check the account default, then the user and list defaults for the audiences you manage. If you plan to use Individual (consented), review the disclosure shown to subscribers, the legacy-contact policy and the placement of the preference link in your messages. If you plan to use Aggregate, check that the required tracking key is configured. The upgrade and deployment notes cover those steps and the reporting changes in detail.
IEM provides the controls and records the choices made through them. The instance owner chooses the mode for each audience and the wording recipients see. Read the Garante’s guidance and obtain your own advice when making those decisions.
Where to go next
- Read the 8.8.0 upgrade and deployment notes for the settings, tracking key, scheduled cleanup and reporting changes.
- Read the France/CNIL operator guide for its separate source material and product walkthrough.
