Mr Larry Page
1600 Amphitheatre Parkway
California, 94043 USA
Dear Mr Page
Initially, I would like to say that the TWG recognises Google’s efforts in making its privacy policies simpler and more understandable. Similarly, it notes Google’s education campaign announcing the changes. However, the TWG would suggest that combining personal information from across different services has the potential to significantly impact on the privacy of individuals. The group is also concerned that, in condensing and simplifying the privacy policies, important details may have been lost.
I would emphasise that members of APPA operate independently in differing regulatory environments. There may, therefore, be issues that are specific to particular jurisdictions. The following comments, however, represent some common concerns raised by the TWG.
1. User choice and control
We understand that the move to a single account will primarily affect new Google account holders. We would be interested to understand how the changes will affect existing users, who may hold several accounts for different Google products, including Google Apps accounts.
We welcome Google’s efforts in developing a number of privacy tools such as the Dashboard and the Opt-out in the Ads Preference Manager. We would question, however, whether users can access these tools readily. We would encourage Google to ensure that these tools are easy to locate and that the Dashboard enables users to view all information associated with their account, including telephone numbers and device identifiers if these are held.
2. Level of detail in the policy
3. Impact on Android users
I look forward to your response to these issues.
Australian Privacy Commissioner
28 February 2012
 APPA comprises the following privacy authorities: Office of the Australian Information Commissioner, Australia; Office of the Information and Privacy Commissioner, British Columbia, Canada; Office of the Privacy Commissioner, Canada; Office of the Privacy Commissioner for Personal Data, Hong Kong; Korea Internet & Security Agency, Korea; Federal Institute for Access to Information and Data Protection, Mexico; Office of the New South Wales Privacy Commissioner, Australia; Office of the Privacy Commissioner, New Zealand; Office of the Northern Territory Information Commissioner, Australia; Office of the Information Commissioner, Queensland, Australia; Federal Trade Commission, United States of America; Office of the Victorian Privacy Commissioner, Australia. The US Federal Trade Commission is not a signatory to this letter.