DPIA Google G Suite Enterprise for SLM Rijk | 9 July 2020, with update 12 February 2021
In this report, the term functional data is used for all data that are only necessary for a short period of time, to be able to communicate with Google’s cloud services. Examples of such functional data are the Customer Data and the Diagnostic Data processed by an email server to deliver the communication, and the data stream necessary to allow the end user to authenticate or to verify if the end user has a valid Google Account. According to the distinction between the three categories of data made in this report, functional data may also include the content of text end users want to have translated or spellchecked. In these cases, it is necessary for Google as a cloud provider to collect the context, to provide better spelling or translation. The key difference between functional data and Diagnostic Data as defined in this report, is that functional data are and should be transient.24 This means that these data should be immediately deleted or anonymised upon completion of the transmission of the communication. Otherwise they qualify as Customer Data or Diagnostic Data. As long as Google does not store these functional data, they are not Diagnostic Data.
G Suite Core Services, Google Account, Support Services, Additional Services, and Other related services As explained in the Introduction, this report describes five key elements of the G Suite Enterprise offering. 1. 2. 3. 4. 5.
Core Services, including Features such as the Spellchecker; Google Account; Technical Support Services Additional Services, and; Other related services that may send Customer Data to Google, such as Feedback and the Enhanced Spellcheck in the Chrome browser.
Figure 2 below shows an overview of the Core Services and the Additional Services.
Compare Article 6(1) of the EU ePrivacy Directive (2002/58/EC, as revised in 2009 by the Citizens Rights Directive) and explanation in recital 22: “The prohibition of storage of communications and the related traffic data by persons other than the end users or without their consent is not intended to prohibit any automatic, intermediate and transient storage of this information in so far as this takes place for the sole purpose of carrying out the transmission in the electronic communications network and provided that the information is not stored for any period longer than is necessary for the transmission and for traffic management purposes, and that during the period of storage the confidentiality remains guaranteed.” 24
p. 20/162
