The analysis of Google's answers and the examination of numerous documents and technical mechanisms by the CNIL's experts have led EU Data protection authorities to draw their conclusions and make recommendations to Google.
Under the current Policy, a Google service's user is unable to determine which categories of personal data are processed for this service, and the exact purposes for which these data are processed.
Moreover, passive users (i.e. those that interact with some of Google's services like advertising or ‘+1' buttons on third-party websites) have no information at all.
EU Data protection authorities remind Google and internet companies in general that shorter privacy notices do not justify a reduction of information delivered to the data subjects.
The European DPAs note that this combination pursues different purposes such as the provision of a service requested by the user, product development, security, advertising, the creation of the Google account or academic research. The investigation also showed that the combination of data is extremely broad in terms of scope and age of the data.
E.g.: the mere consultation of a website including a ‘+1' button is recorded and kept during at least 18 months and can be associated with the uses of Google's services; data collected with the DoubleClick cookie are associated to a identifying number valid during 2 years and renewable.
European Data Protection legislation provides a precise framework for personal data processing operations. Google must have a legal basis to perform the combination of data of each of these purposes and data collection must also remain proportionate to the purposes pursued. However, for some of these purposes including advertising, the processing does not rely on consent, on Google's legitimate interests, nor on the performance of a contract.
Google refused to provide retention periods for the personal data it processes.
Several recommendations are also supported by members of APPA (Asia Pacific Privacy Authorities) and Canada's federal Privacy Commissioner has had similar concerns about various Google activities.
The CNIL, all the authorities among the Working Party and data protection authorities from other regions of the world expect Google to take effective and public measures to comply quickly and commit itself to the implementation of these recommendations.