Privacy Battles
Google Analytics
Privacy Score
50
%
⚔️
AT Internet
Privacy Score
86
%

Designated DPO or GDPR correspondent

Compliant
Partially Compliant
Not Compliant

Google doesn't mention having a DPO but has a privacy dedicated help center which contact is available on its website: https://support.google.com/policies/answer/9581826?hl=en&visit_id=637842217867882507-4117401368&rd=1 

Compliant
Partially Compliant
Not Compliant

AT Internet has appointed a Data Protection Officer who can be contacted at the following address: dpo@atinternet.com or by post.

Privacy Policy

Compliant
Partially Compliant
Not Compliant

Regarding cloud & website: https://policies.google.com/privacy 

This policy however covers a broad scope that includes various Google applications and services (including Analytics), that makes it difficult to apprehend for both controllers and data subjects.

Country & Type of Data storage

Compliant
Partially Compliant
Not Compliant

Company Headquarters:
Ireland (EU)

Storage Facilities:
Google has cloud servers all over the world but (except for the US) doesn’t specify in which countries.

Compliant
Partially Compliant
Not Compliant

Company Headquarters:
France 🇫🇷  (EU) 🇪🇺

Storage Facilities:
All analytics data is stored in the EU by cloud providers AWS and SFR.

AT Internet however doesn’t specify in which country data is hosted.

Data transfers outside the EU

Compliant
Partially Compliant
Not Compliant

Personal data is transferred outside the European Union whether this transfers are based on Adequacy decisions of the European Commission or Standard contractual clauses (SCCs).

However, SCCs have been deemed insufficient when transferring personal data to US servers by the European Court of Justice. This entails the necessity for complementary data protection measures. However, the French Data Protection Authority (CNIL) has considered complementary measures put in place by Google (User ID pseudonymisation, IP addresses anonymisation, etc.) not efficient enough for data protection against intelligence agencies.

Compliant
Partially Compliant
Not Compliant

AT Internet doesn’t transfer analytics data outside the EU.

Legal tools for Subcontractors

Compliant
Partially Compliant
Not Compliant

Subcontractors are subjects to written agreements substantially similar to Google’s DPA: https://business.safety.google/intl/en/adsprocessorterms/

Google has made public its list of subprocessors:
https://business.safety.google/intl/en/adssubprocessors/

Before onboarding subprocessors, Google conducts an audit of the security and privacy practices of subprocessors to ensure they provide a level of security and privacy appropriate to their access to data and the scope of the services they are engaged to provide.

‍30 days prior to modifying the list of subprocessors, the controller will be notified by email and is able to object by terminating the contract.

Compliant
Partially Compliant
Not Compliant

At Internet commits itself to verify that its subcontractors present sufficient guarantees regarding the implementation of technical and organizational measures.

AT Internet has made public its list of subprocessors: https://www.atinternet.com/en/processor-sub-processor-information-parent-company/

Prior to modifying the list of subprocessors, the controller will be notified and is able to object.

Data Breach Notification

Compliant
Partially Compliant
Not Compliant

If Google becomes aware of a Data Incident, Google will notify controllers promptly and without undue delay; and promptly take reasonable steps to minimise harm and secure personal data. Google will deliver its notification by email, phone call or an in-person meeting.

Compliant
Partially Compliant
Not Compliant

In case of a data breach, AT Internet will notify the controller without undue delay after becoming aware of the breach, and provide the necessary information to notify Data Protection Authorities.

Right Requests Process

Compliant
Partially Compliant
Not Compliant

Rights of deletion and portability can be fulfilled by the controllers directly through the SaaS.

If Google receives a request from a data subject, controllers authorize Google to answer directly to the data subject’s request or to advise the data subject to submit their request to the appropriate controller.

Google commits to assist controllers in fulfilling their obligations to respond to requests for exercising the data subject’s rights.

Compliant
Partially Compliant
Not Compliant

Data request will be forwarded to the controller without delay and assistance will be provided to the controller to answer any request.

Data Privacy Impact Assessment

Compliant
Partially Compliant
Not Compliant

Google assists controllers in ensuring compliance with their obligations in respect of DPIAs and prior consultation.

Compliant
Partially Compliant
Not Compliant

AT Internet will provide necessary assistance to the controller in case of Data Privacy Impact Assessment on an analytics processing activity.

Employee Trainings

Compliant
Partially Compliant
Not Compliant

Google ensures all persons authorised to process personal data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality.

Compliant
Partially Compliant
Not Compliant

Employees are trained on the confidentiality of personal data and subjects to a strict confidentiality obligation.

Security Policy

Compliant
Partially Compliant
Not Compliant

Google has obtained and maintained an ISO 27001 certification, for which a security policy is necessary.

Compliant
Partially Compliant
Not Compliant

AT Internet mentions having a security policy and updating it regularly, but has not made it public.

Organizational and Technical Security Measures

Compliant
Partially Compliant
Not Compliant

Server security:
Cloud security relying on Google Cloud (on-site security operations, formal physical access procedures, CCTV, biometric controls, etc.)

Other measures:
Backup redundancy, code review, business continuity plan, data encryption, intrusion detection controls, incident monitoring, employee security trainings, user authentication (strong passwords, 2-factor authentication), authorization management, data pseudonymisation (user ID).

Compliant
Partially Compliant
Not Compliant

AT Internet mentions having a security policy and updating it regularly, but has not made it public.

Data Encryption

Compliant
Partially Compliant
Not Compliant

Data encryption in transit (HTTPS) and at rest (AES256).

Compliant
Partially Compliant
Not Compliant

AT Internet never mentions data encryption.

Restriction of access

Compliant
Partially Compliant
Not Compliant

Access to data by employees, contractors, and subcontractors is limited by strict access controls (authentication procedures, SSL, and security logs), restricting access only to authorized users.

Compliant
Partially Compliant
Not Compliant

AT Internet limits access to data only to persons who need to know and does not share data with third parties without prior demand of the controller.

Reuse of data

Compliant
Partially Compliant
Not Compliant

Google shares personal data between its multiple service platforms (Adsense, etc.).

Concerning third parties, Google states it will not use or disclose any confidential information belonging to controllers without their prior written consent, except to fulfill its obligations under this Agreement or as required by law, regulation or court order.

Compliant
Partially Compliant
Not Compliant

AT Internet doesn’t pursue its own purposes with this data processing. The controller stays the data owner.

Exemption of cookie consent

Compliant
Partially Compliant
Not Compliant

NO, by default Google collects cookies and therefore visitors’ consent is necessary.

Compliant
Partially Compliant
Not Compliant

YES, if controller masks the following personal data by default (visitor ID, postal code, internet service provider, converted visit) and anonymizes IP addresses.

Submission to Cloud Act/FISA

Compliant
Partially Compliant
Not Compliant

YES, even though Google offers an anonymisation option for IP addresses that can be activated by controllers, other personal data is still transferred on US servers by default (user ID, cookies).

Also, Google publishes a Transparency Report which is a list of demands based on FISA made by intelligence agencies:
https://transparencyreport.google.com/user-data/us-national-security

Compliant
Partially Compliant
Not Compliant

YES, data hosted on Amazon servers doesn’t appear to be anonymized nor encrypted at rest, therefore can be accessed by an American intelligence agency on demand.