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

account data as processor. Only when end users access Additional Services, such as Search or Youtube, does Google process the Google Account data as data controller. However, at the time of completion of this DPIA, Google’s role as a data processor for the processing of personal data relating to the Google Account Data and the Features was not contractually guaranteed. Furthermore, Google does not act as a data processor for the Diagnostic Data collected about the use of the Core Services, the Features, the Google Account, the Additional Services and related services such as the Feedback form and the enhanced spellchecker in the Chrome browser. Google objects against the analysis of its role as a joint controller with its customers for the Diagnostic Data (including the telemetry and the cookie/website data). This objection is reflected in the DPIA, but did not lead to a different analysis (See Section 5.4 of this DPIA). Purposes Google disagrees with the list of purposes identified in this report, as it considers those purposes to be examples of processing activities, and not purposes. Google states that it only has one purpose for the processing of Customer Data as data processor: “As documented in Section 5.2.1 of the G Suite DPA Google is only contractually permitted to process Customer Personal Data according to the documented instructions of our customer described in that section. This includes an overall instruction to provide the services”. Google refused to provide an exhaustive list of purposes for which it processes the different categories of Diagnostic personal Data on the use of G Suite Enterprise. At the moment of completion of this DPIA, in July 2020, Google committed to drafting a new Enterprise Privacy Notice that will provide explicit and specific purposes for which Google processes personal data that Google collects or generates that are not personal data in Customer Data. On 12 November 2020 Google published a Google Cloud Privacy Notice with a list of purposes.14 Google’s interests in the use of Diagnostic Data for personalised advertising Part A describes that Google permits itself in its (consumer) Privacy Policy to use of Diagnostic Data for advertising purposes. In the technical inspection occurrence of a DoubleClick cookie was observed during the log-in to the G Suite Enterprise Core Services. Google disagrees with the conclusion that Google has an interest in the use of Diagnostic Data for advertising purposes, and clarified that the DoubleClick cookie was a bug which since has been fixed. Outline This assessment follows the structure of the Model Gegevensbeschermingseffectbeoordeling Rijksdienst (PIA) (September 2017).15 This model uses a structure of four main sections, which are reflected here as “parts”. 1. 2. 3. 4.

Description of the factual data processing Assessment of the lawfulness of the data processing Assessment of the risks for data subjects Description of mitigation measures

Google, Google Cloud Privacy Notice, 7 December 2020, URL: https://cloud.google.com/terms/cloud-privacy-notice 15 The Model Data Protection Impact Assessment federal Dutch government (PIA). For an explanation and examples (in Dutch) see: https://www.rijksoverheid.nl/documenten/ rapporten/2017/09/29/modelgegevensbeschermingseffectbeoordeling-rijksdienst-pia 14

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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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