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DPIA Google G Suite Enterprise for SLM Rijk | 9 July 2020, with update 12 February 2021

Education.221 This means children become accustomed to a ‘free’ Gmail address at a very young age, which they may likely to keep on using when they grow up. Google has a clear financial, business and economic interest in certain default settings. Google explained that all Additional Services are turned on by design. Some Additional Services contain and generate personalised advertising. As one of the world’s biggest ad networks, Google has a strong financial interest in the delivery of ads, in particular targeted ads. Google believes that by showing personalised ads it is delivering value to online end users, since they do not have to pay with money for many services.222 In 2019, Google gained a revenue of approx. 134 billion US dollar with its advertising business.223 In 2019, Google cloud revenues amounted to only 5.5% of its global revenues.224 These cloud revenues consist primarily of revenues from Google Cloud Platform (GCP). This includes infrastructure, data and analytics, and other services such as G Suite and other enterprise cloud services.225

6.3

Joint interests The interests of Google and the Dutch government align when it comes to the use of data for security purposes. An example is the use of Diagnostic Data to protect personal data stored in, or generated by the use of, the G Suite services against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access, and by restoring timely access to personal data following an incident. Google’s interest in developing new services and improving or expanding functionalities can also be aligned with the interests of the Dutch government organisations, provided that such new services or improvements follow the restrictions set by administrators, and are not activated by default. Similarly, Google and government organisation’s interests may be aligned in the processing of some personal data by Google to deliver well-functioning (bug free) services, to prevent loss of labour capacity for the Dutch government. In sum, Google has financial, economic and commercial/business interests to provide secure and innovative services. Google also has strong commercial/business interests in default settings that allow frictionless use of its Additional Services and that maximise the collection of Diagnostic Data. Some interests are consistent with the Dutch government’s interests, but others are not.

Item in Dutch national newspaper De Volkskrant, Google wordt steeds grotere speler op scholen, tot zorg van privacyorganisaties, 1 november 2019, URL: https://www.volkskrant.nl/nieuws-achtergrond/google-wordt-steeds-groterespeler-op-scholen-tot-zorg-van-privacyorganisaties~bae18dcd/ 222 See for example Google, Our Privacy and Security Principles, URL: https://safety.google/principles/ “We also use data to serve more relevant ads. While these ads help fund our services and make them free for everyone, it’s important to clarify that our users’ personal information is simply not for sale.” Or Understanding how Google ads work, URL: https://safety.google/privacy/ads-anddata/ “We use data to make our services more useful and to show relevant advertising, which helps make our services free for everyone.” 223 Statista, Annual revenue of Google from 2002 to 2019, 5 February 2020, URL: https://www.statista.com/statistics/266206/googles-annual-global-revenue/ In the most recently reported fiscal year, Google's revenue amounted to 160.74 billion US dollars. Google's revenue is largely made up by advertising revenue, which amounted to 134.81 billion US dollars in 2019. See also Alphabets 10K filing at the US Security and Exchange Commission over 2019, URL: https://www.sec.gov/cgibin/viewer?action=view&cik=1652044&accession_number=0001652044-20000008&xbrl_type=v. According to this filing, the revenu was 161.857 million USD. 224 Idem, Distribution of Google segment revenues from 2017 to 2019, URL: https://www.statista.com/statistics/1093781/distribution-of-googles-revenues-bysegment/ 225 Ibid. 221

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Conclusions

2min
page 170

17.4 Google measures 12 February 2021

19min
pages 161-169

16.3 Summary of risks

2min
pages 155-156

16.2 Assessment of Risks

36min
pages 142-154

15.7 Right to file a complaint

0
page 139

15.3 Right to access

5min
pages 136-137

14.3 Assessment of the subsidiarity

2min
page 134

14.1 The principle of proportionality

2min
page 130

14.2 Assessment of the proportionality

8min
pages 131-133

12.1 Transfer of special, sensitive, secret and confidential data to the USA

5min
pages 128-129

11.3 Google’s own legitimate business purposes

5min
pages 126-127

all Diagnostic Data

5min
pages 124-125

Services

22min
pages 116-123

Part B. Lawfulness of the data processing

2min
page 115

8.1 Anonymisation

15min
pages 106-111

6.3 Joint interests

11min
pages 101-105

6.2 Interests of Google

2min
page 100

6.1 Interests of the Dutch government organisations

2min
page 99

5.2 Data processor

5min
pages 88-89

5.3 Data controller

18min
pages 90-96

5.4 Joint controllers

5min
pages 97-98

4.4 Specific purposes Chrome OS and the Chrome browser

2min
page 86

5.1 Definitions

2min
page 87

4.3 Purposes Additional Services and Google Account, when not used in a Core Service

8min
pages 83-85

4.2 Purposes Google

13min
pages 77-82

4.1 Purposes government organisations

2min
page 76

2.5 Types of personal data and data subjects

7min
pages 60-62

3.2 Privacy controls administrators

7min
pages 70-75

3.1 Privacy controls G Suite account for end users

9min
pages 63-69

2.3 Outgoing traffic analysis

8min
pages 52-55

2.4 Results access requests

10min
pages 56-59

2.2 Diagnostic Data

7min
pages 47-51

Related services that may send Customer Data to Google, such as the Feedback form and the Enhanced Spellchecker in the Chrome browser.

4min
pages 13-15

2.1 Definitions of different types of personal data

7min
pages 44-46

Part A. Description of the data processing

0
page 25

The enrolment framework for G Suite Enterprise

2min
pages 42-43

G Suite Core Services, Google Account, Support Services, Additional Services, and Other related services

23min
pages 28-41

Functional Data

2min
page 27

Introduction

7min
pages 16-18

1 Legal framework and contractual arrangements between government organisations and

4min
pages 23-24
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