After having analysed Google’s response received at the end of April, the CNIL sent to Google an additional questionnaire on 22 May 2012 in which the CNIL merely asks for a precise description, for each of its previous questions, of the data processing implemented by Google, and considers Google’s approach, which was done based on examples, as non-sufficient. This letter was issued just before a meeting with Google 23 May in Paris.
If the general tone of the CNIL’s President, Mrs. Falque-Pierrotin, to Google’s CEO Larry Page is very amicable, the CNIL’s notes on this letter, published again on CNIL’s website, in English, show how deep the CNIL’s concerns are:
- The CNIL still considers it impossible to know Google’s processings of personal data
- It concludes that there is still no clarification regarding the links between collected data, purposes and recipients
- It also considers that the obligation of information of the data subjects is not respected
- The CNIL notes that Google has not provided a maximum retention period for the data
- It also wants to clarify the effects of Google’s opt-out mechanisms and their validity with respect to the right to oppose
- The CNIL lacks Google’s answer as to the treatment of “passive users” defined as users of Google’s services (advertising, analytics, +1 button) when they visit third-party websites
Google is due, according to the schedule set forth by the CNIL, to answer until 8 June 2012 to this additional questionnaire.
The CNIL will then provide its conclusions to the Working Party 29 by mid-July.