On 30 January 2015, Google signed an Undertaking with the Information Commissioner's Office (ICO) to improve and amend the Privacy Policy it adopted 1 March 2012.
Among other things, the modifications to the Privacy Policy allowed Google to combine personal data across all services and products. For example, personal data collected through YouTube could now be combined with personal data collected through Google Search.
The Undertaking requires Google to address three of the ICO's particular concerns: (1) the lack of easily accessible information describing the ways in which service users' personal data is processed by Google; (2) the vague descriptions describing the purposes for which the personal data is processed; and (3) the use of insufficient explanations of technical terms to service users.
In order to address these issues, Google states in Annex 1, Undertaking that it will, inter alia: enhance the accessibility of its Privacy Policy to ensure that users can easily find information about its privacy practices; provide clear, unambiguous and comprehensive information regarding data processing, including an exhaustive list of the types of data processed by Google and the purposes for which data is processed; and revise its Privacy Policy to avoid indistinct language where possible.
Google has a period of two years in which to implement these changes, and it must provide a report to the ICO by August 2015, specifying the steps Google has taken in response to the commitments set out in the Undertaking.
The ICO's measures in response to Google's breach of national data protection laws are much lighter than those take by other EU Member States. The data protection authorities in France (CNIL) and Spain (AEPD) have imposed fines of €150,000 and €900,000 respectively. Currently, the Dutch data protection authority is threatening Google with a €15 million fine (see our previous blog).
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