The Art. 29 Party, which includes representatives from the EU's 28 member state data protection authorities, suggested in their recommendations that Google take several steps to move the unified policy closer to EU data protection principles, including that it “provide users with more elaborate tools to manage their personal data and to control the usage of their personal data between all Google services.”
The Art. 29 Party transmitted the list of recommendations as an attachment to a Sept. 23 letter to Google Chief Executive Officer Larry Page.
The use of “we may” or “we can” should be replaced in the policy with clear information on data collection and use, such as “if you use services A and B, we will,” the recommendation document said.
• be immediately visible and accessible to users, “for instance visible without scrolling and accessible via one click, from each service landing page;”
• provide clear, unambiguous and comprehensive information on the types of personal data processed and all of the purposes for which the data may processed;
• provide contact identity and contact information “so that individuals can exercise their rights,” in particular for services that users might not understand are controlled by Google, such as YouTube; and
• be displayed on all platforms and devices directly or through a required interface to configure it.
The Art. 29 Party made specific notification suggestions to alert “passive users” of Google services, such as data collection Google Analytics software and DoubleClick's targeted advertising systems.
The Art. 29 Party also said that Google should inform EU data protection authorities of its policies regarding retention of user data. The group and Google have long disagreed about how long the company should be allowed to hold on to user data for research and other uses.
The recommendation document said that Google should retain data in compliance with the proportionality principle.
The group also said Google should disclose to users and privacy regulators the anonymization processes it uses. It encouraged Google to assess whether its anonymization techniques comply with the Art. 29 Party's opinion on anonymization.
The Art. 29 recommendations, “Appendix : List of possible compliance measures,” is available at http://ec.europa.eu/justice/data-protection/article-29/documentation/other-document/files/2014/20140923_letter_on_google_privacy_policy_appendix.pdf.
The Art. 29 Party letter to Google CEO Larry Page is available at http://ec.europa.eu/justice/data-protection/article-29/documentation/other-document/files/2014/20140923_letter_on_google_privacy_policy.pdf.
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