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Posted by Peter Fleischer, Global
Privacy Counsel

Over the years we’ve taken many steps to protect our users'
data and privacy. For example, we have resisted href="http://googleblog.blogspot.com/2006/02/response-to-doj-motion.html" >
overly-broad government subpoenas; we've designed our
services to give users a choice between href="http://googleblog.blogspot.com/2007/02/personally-speaking.html" >
personalized services and general services; and we've
engineered our services to allow users href="https://www.google.com/accounts/ServiceLogin?hl=en&continue=http://www.google.com/history/?zx=8TejGP12Uv4&nui=1&ltmpl= reauth&service=hist&srr=1" >
to see and control how much data they wish to share with us.
Recently, we took another important step to improve our privacy
practices by announcing href="http://googleblog.blogspot.com/2007/03/taking-steps-to-further-improve-our.html" >
a new policy to anonymize our server logs after 18 to 24
months, becoming the first leading search company to publish a data
retention policy. We also posted here to

href="http://googleblog.blogspot.com/2007/05/why-does-google-remember-information.html" >
explain the factors that guided our decision to retain server
log data for 18 to 24 months.

The Article 29 Working Party, an advisory panel composed of
representatives from all of the E.U.'s national data protection
authorities, has sent us a href="http://ec.europa.eu/justice_home/fsj/privacy/news/docs/pr_google_16_05_07_en.pdf" >
letter in response to our commitment to anonymize server logs.
In it, they're asking us to provide further information about
our new policy, and to explain why we feel that the time period of
18 to 24 months is “proportionate” under European data protection
principles. For some time, we've discussed many things with the
Working Party, ranging from issues raised by Google products like
Gmail and Google Desktop to industry-wide concerns, such as the
challenges of protecting privacy in the Web 2.0 era. We’re pleased
that this most recent letter from the Working Party acknowledges
our ongoing engagement with the data protection community and, in
particular, our "readiness to consult with it [the Working
Party] in contrast with a relative lack of engagement by some of
the other leading players in the search engine community”.

In the spirit of transparency, we're publishing href="http://64.233.179.110/blog_resources/Google_response_Working_Party_06_2007.pdf" >
our response to the Working Party's letter. The Internet is
a global medium, and the principles at stake — privacy, security,
innovation and legal obligations to retain data — have an impact
beyond Europe, and outside of the realm of privacy. These
principles sometimes conflict: while shorter retention periods are
good for privacy, longer retention periods are needed for security,
innovation and compliance reasons. We believe we’ve struck a
reasonable balance between these various factors. Our policies are
consistent with EU data protection laws, which acknowledge the need
to set data retention periods that are proportionate and that
enable companies like Google to comply with legal
requirements.

We have a legitimate interest in retaining search server logs for a
number of reasons:

to improve our search algorithms for the benefit of users

to defend our systems from malicious access and exploitation
attempts

to maintain the integrity of our systems by fighting click
fraud and web spam

to protect our users from threats like spam and phishing

to respond to valid legal orders from law enforcement as they
investigate and prosecute serious crimes like child exploitation;
and

to comply with data retention legal obligations.

After considering the Working Party's concerns, we are
announcing a new policy: to anonymize our search server logs after
18 months, rather than the previously-established period of 18 to
24 months. We believe that we can still address our legitimate
interests in security, innovation and anti-fraud efforts with this
shorter period. However, we must point out that future data
retention laws may obligate us to raise the retention period to 24
months. We also firmly reject any suggestions that we could meet
our legitimate interests in security, innovation and anti-fraud
efforts with any retention period shorter than 18 months. We are
considering the Working Party's concerns regarding cookie
expiration periods, and we are exploring ways to redesign cookies
and to reduce their expiration without artificially forcing users
to re-enter basic preferences such as language preference. We plan
to make an announcement about privacy improvements for our cookies
in the coming months.

As we build new products and services, we look forward to
continuing our discussion with the Article 29 Working Party and
with privacy stakeholders around the world. Our common goal is to
improve privacy protections for our users.

Tags: , CounselOver, Fleischer, Global, Peter, Posted, Privacy, years