4 ms·
> the legal reason in the first column In GDPR terms, the "Legal Basis" is one of the following six values[1]: Vital Interest Public Benefit Legal Oblig
by lmkg 7y ago
> the legal reason in the first column
In GDPR terms, the "Legal Basis" is one of the following six values[1]:
Vital Interest
Public Benefit
Legal Obligation
Performance of Contract
Legitimate Interest
Consent
"Accounting" is not a Legal Basis.
Several might apply, including Legal Obligation, Performance of Contract, Consent, or Legitimate Interest. Stating the Legal Basis for processing is one of the requirements under the Right to Transparency[2]. Among other things, the Legal Basis affects other rights the Data Subject has. E.g. the Right to Erasure is much stronger for data collected under Consent than Legal Obligation.
On the face of it, it looks to me that Brave has a point: Google is not complying with some (frankly, rather simple) transparency requirements.
[1] GDPR Article 6 Section 1: https://gdpr-info.eu/art-6-gdpr/ https://gdpr-info.eu/art-6-gdpr/.
[2] GDGPR Article 13 Section 1(c): https://gdpr-info.eu/art-13-gdpr/ https://gdpr-info.eu/art-13-gdpr/
- tqi 7y agoI couldn't find the exact line from the citation in the pdf[1], but I assume "Accounting" means financial accounting ("For example, when you purchase apps from the Play Store or products from the Google Store."), which is a legal obligation? [1] https://policies.google.com/technologies/retention#purpose-financial https://policies.google.com/technologies/retention#purpose-f...)
- lmkg 7y agoThe fact that you have to guess is exactly the problem ;) Accounting for SEC filings or whatnot are legal obligations. But processing an individual payment is also probably part of Performance of Contract, and Google explicitly mentions fraud detection on that same page, which is usually Legitimate Interest. To say nothing of whether that financial data is compiled into a user profile or used to train a model in some way.