I use a wireless sensor mounted underneath a gutter north facing so it never gets sunlight whatever the month or time.
On a different note, when I was studying Ecology with the Open University, we had to do an experiment putting thermometers underneath an oak tree and another exposed to the elements. It started in October and the idea was that the difference between the two got smaller as the tree lost its leaves. When the group collated the results someone obviouslt hadnt covered the exposed one in leaves so they reported a temp of about 47 degrees because the direct sunlight in November was that strong! Shows what a difference direct sunlight can give.