The French data protection regulator, CNIL, the Article 29 Working Party’s lead authority on issues affecting the new Google privacy policy, has sent a letter with a questionnaire attached seeking Google’s responses to a series of concerns. The letter to Google, dated 16 March, and the questionnaire have now been published: click here for the full text.
SCL members will recall that the Article 29 Working Party expressed considerable concern about the combination of personal data across services: they referred to strong doubts about the lawfulness and fairness of such processing, and about its compliance with European Data Protection legislation, especially with Articles 6 and 7 of the Data Protection Directive. Originally, the concerns seemed mainly to relate to the failure to fully explain the policy to users but, following Google’s refusal to delay the implementation of the new policy, the objections appear to have widened.
There are 69 ‘questions’ – some are in fact requests for information. It would no doubt be a service to readers for the Editor to highlight those which go to the root of the Working Party’s objections to the policy but the questionnaire is full of questions which reveal the nature of the Working Party’s concerns – many are not merely pointed questions but barbed too.
