Privacy Evaluation for Google Family Link
Google Family Link lets parents for children under 13 create a Google Account for their child that's like their own account, with access to most Google services, but stronger privacy protections. Google's terms state that many of its services let users interact with other trusted and untrusted users and share information with other people, for example, people with whom a user chooses to communicate or share content. The terms state Google may use users' personal information to provide third-party marketing, but disclose they do not sell users' personal information to third parties. Google's terms also state they will not serve personalized ads to a child, which means ads will not be based on information from a child’s account. Instead, ads may be based on information like the content of the website or app a parent's child is viewing, the current search query, or general location (such as city or state). However, Google’s terms state they also allow specific partners to collect information from browsers or devices for third-party advertising and measurement purposes using their own cookies or similar technologies.
Additionally, other relevant policies used for this evaluation include:
- Our Privacy and Security Principles
- Devices Terms of Sale
- Google's Subprocessors
- Google Payments Privacy Notice
- Legal Frameworks For Data Transfers
- Google’s Partners
- Google Advertising
- Type of cookies used by Google
- Export your organization's data
- Google Cloud Privacy
- Google Cloud Security
Google's terms state that many of its services let users interact with other trusted and untrusted users and share information with other people, for example, people with whom a user chooses to communicate or share content. If a user has a Google Account, they may display their profile name, profile photo, and actions a user takes on Google or on third-party applications connected to their Google Account. Additionally, a child’s information, including their name, photo, email address, and Google Play purchases, may be shared with members of a family group with Google Family Link.
Google's terms remind users that when they share information publicly, their content may become accessible through search engines, including Google Search. When a user is signed-in and interacts with Google services, like leaving comments on a YouTube video or reviewing a song in Google Play, their name and photo appear next to their activity. The terms state users may manage their contact information, such as their name, email, and phone number, and choose whether their name and photo appears next to their activity, like reviews and recommendations, that may also appear in ads depending on their shared endorsements setting.
The terms also state a child will be able to share information, including photos, videos, audio, and location, publicly and with others, when signed in with their Google Account. When a child shares information publicly, it may be accessible through search engines like Google Search. Google Dashboard is a service that allows users to manage information associated with specific products and control what others see about a user across Google services. In addition, the terms state that Google provides "My Activity" controls that allow users to review and control data that are created when they use Google services, like searches they have done, or visits to Google Play. Users can also browse by date and by topic, and delete part or all of their activity on Google services.
Google provides additional safety resources for families:
Google's terms state that they build a range of services that help millions of people daily to explore and interact with the world in new ways. The terms state Google understands it needs to build privacy that works for everyone, which is a responsibility that comes with creating products and services that are free and accessible for all. The terms state Google uses these principles to guide their products, their processes, and their people in keeping users’ data private, safe, and secure. The terms also state that users may provide information to Google which personally identifies them, such as their name, email address, or billing information, or other data that can be reasonably linked to a user by Google, such as information they associate with their Google Account.
In addition, Google's terms state they collect information about a child’s activity in their services, which they use to do things like recommend apps they might like on Google Play. A child’s activity information that they collect may include things like search terms, videos they watch, voice and audio information when they use audio features, people with whom they communicate or share content, and Chrome browsing history they’ve synced with their Google Account. If a child uses Google's services to make and receive calls or send and receive messages, for example by using Google Hangouts, Google may collect telephony log information. The terms state a child can visit their Google Account to find and manage activity information that’s saved in their account and parents can also manage their activity information by signing in to their child’s Google Account.
When it comes to privacy, Google's terms state they know one size doesn’t fit all. Every Google Account is built with on/off data controls, so users can choose the privacy settings that are right for them. And as technology evolves, Google's terms state its privacy controls evolve as well, ensuring that privacy is always an individual choice that belongs to the user. The terms state Google may use users' personal information to provide third-party marketing, but disclose they do not sell users' personal information to third parties. In addition, the terms state Google may display targeted advertisements to users, but that users can modify their interests, and choose whether their personal information is used to make ads more relevant to them, and turn on or off certain advertising services. The terms also state that Google allows specific partners to collect information from a user's browser or device for advertising and measurement purposes using their own cookies or similar technologies.
However, Google's terms state they will not serve personalized ads to a child, which means ads will not be based on information from a child’s account. Instead, ads may be based on information like the content of the website or app a parent's child is viewing, the current search query, or general location (such as city or state). However, Google’s terms state they also allow specific partners to collect information from browsers or devices for third-party advertising and measurement purposes using their own cookies or similar technologies. Additionally, the terms state Google does not collect or use data in Google Cloud or G Suite services for advertising purposes and there are no ads in G Suite Services or Google Cloud Platform. Lastly, Google's terms state they don’t show users personalized ads based on sensitive categories, such as race, religion, sexual orientation, or health.
Google provides additional privacy resources:
Google's terms state they respect the privacy of their users which means protecting the data they trust Google with. This means constantly strengthening Google's built-in security technologies to detect and protect against evolving online threats, before they ever reach Google's users. However, the terms state keeping users safe online doesn’t stop with Google – it extends to the whole Internet. Google explains it was the first company to create many of the security standards we all use today, and Google continues to innovate new security technologies that can be used by everyone. The terms also state Google shares their security learnings, experiences, and tools with partners, organizations, and competitors around the world, because Internet-wide security demands industry-wide collaboration.
The terms state Google reviews their information collection, storage, and processing practices, including physical security measures, to prevent unauthorized access to their systems. Google's terms state they restrict access to personal information to Google employees, contractors, and agents who need that information in order to process it. Anyone with this access is subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations. Before on-boarding third-party subprocessors, Google conducts an audit of the security and privacy practices of subprocessors to ensure subprocessors provide a level of security and privacy appropriate to their access to data and the scope of the services they are engaged to provide. In addition, the terms state Google uses encryption to keep users' data private while in transit with SSL (Secure Sockets Layer)/TLS (Transport Layer Security) and while stored on their servers. The terms state that if Google becomes aware of a data breach incident, Google will notify users of the incident promptly and without undue delay, and promptly take reasonable steps to minimize harm and secure users' data.
Google provides additional security resources:
Google's terms state that they know it’s important for parents and guardians to understand what personal information they collect in association with their child’s Google Account, why they collect it, and how parents can update, manage, export, and delete that information. If a parent or guardian creates a new account for their child with Family Link, they can access, update, remove, and export their child’s information by signing into their Google Account. As part of the account creation process, the terms state Google may ask for personal information like first and last name, email address, and birthdate. Google may also use payment information to verify that a user meets age requirements, if, for example, if a user enters an incorrect birthday indicating they are not old enough to have a Google Account.
When a child turns 13, they are eligible to manage their account on their Google own. If a child chooses to manage their Google Account, their parent or guardian will no longer have access to, or be able to exercise control over their account, unless the parent and their child later choose to set up supervision again through Family Link. In addition, the terms state parents and guardians can also use the Family Link app or Family Link settings on the web to edit or modify their child’s Google Account information, review app activity and app permissions, and manage their child’s ability to grant certain permissions to apps to do things like access information from their child’s mobile device (such as location, microphone, and contacts). Parents can also use Family Link to help manage their child’s access to certain features, apps, and services on Android, or change their Android permissions. Lastly, the terms state if at any time a parent or guardian wishes to stop further collection or use of their child's information, they can delete their child’s Google Account my clicking “Delete account” on their child’s Account Info page in Family Link or on the Family group page in My Account.
What data does it collect?
- Personally identifiable information (PII) is collected.
- The categories of collected personally identifiable information are indicated.
- Collection or use of data is limited to product requirements.
- Geolocation data are collected.
- Biometric or health data are collected.
- Interactions, behaviors, or usage analytics data are collected.
- Sensitive data are collected.
- Data is automatically collected.
- Opt-in consent is requested from users at the time personal information is collected.
- Personal information of users is collected by a third party.
What data does it share?
- Collected information is shared with third parties.
- The categories of information shared with third parties are indicated.
- The purpose for sharing a user's personal information with third parties is indicated.
- The categories of third parties that receive data are indicated.
- Data are shared for analytics.
- Data are shared for research and/or product improvement.
- Third-party services are used to support the product.
- The roles of third-party service providers are indicated.
- Third-party login is supported.
- Contractual limits are placed on third-party data use.
How does it secure data?
- A user's identity is verified with additional personal information.
- Account creation is required.
- Managed accounts are available.
- Multi-factor account protection is available.
- Third-parties with access to information are required to provide the same security protections as the company.
- Reasonable security practices are used to protect data.
- Employee or physical access to user information is limited.
- All data in transit are encrypted.
- All data are stored in an encrypted format.
- Notice is provided in the event of a data breach.
What rights do I have to the data?
- Users can create or upload content.
- Users retain ownership of their data.
- Processes to access or review user data are available.
- Processes to modify data are available for authorized users.
- A data-retention policy is available.
- Processes for authorized users to delete data are available.
- A user's data are deleted upon account cancellation or termination.
- Data are deleted when no longer necessary.
- Methods are available to restrict who has access to data.
- Processes to download user data are available.
Is the data sold?
- Personal information is not sold or rented to third parties.
- Users can opt out from the disclosure or sale of their data to a third party.
- User information can be transferred to a third party in the event of a merge, acquisition, or bankruptcy.
- Users are notified if their information is transferred to a third party.
- Unclear whether user information can be deleted prior to its transfer to a third party.
- Unclear whether third-party transfers are contractually required to use the same privacy practices.
- User information that is shared is shared in an anonymous or de-identified format.
- Unclear whether the company describes their de-identification process of user information.
- Data are shared for research and/or product improvement.
- Unclear whether contractual limits prohibit third parties from reidentifying or de-identified information.
How safe is this product?
- Users can interact with trusted users.
- Users can interact with untrusted users, including strangers and/or adults.
- Profile information must be shared for social interactions.
- Personal information can be displayed publicly.
- Users can control how their data are displayed to others.
- User-created content is reviewed, screened, or monitored by the company.
- Unclear whether user-created content is filtered for personal information before being made publicly visible.
- Unclear whether social interactions between users are moderated.
- Social interactions of users are logged.
- Unclear whether users can report abuse or cyberbullying.
Ads & Tracking
Are there advertisements or tracking?
- Personal information is shared for third-party marketing.
- Traditional or contextual advertisements are displayed.
- Personalised advertising is not displayed.
- Data are collected by third-parties for their own purposes.
- User's information is used to track and target advertisements on other third-party websites or services.
- Data profiles are created and used for personalised advertisements.
- The company can send marketing messages.
- The company does provide promotional sweepstakes, contests, or surveys.
- Users can opt out of contextual, or personalised advertising.
- Users can opt out or unsubscribe from marketing communications.
Can I provide parental consent?
- Intended for children under 13.
- Personal information from children under 13 years of age is collected.
- Intended for parents or guardians.
- Company does have actual knowledge that personal information from users under 13 years of age is collected.
- The company does provide a section, heading, or separate policy for children in their policies.
- Parental consent is required before personal information is collected or disclosed.
- Unclear whether this product limits parental consent with respect to third parties.
- Parents can withdraw consent for the further collection of their child's information.
- Unclear whether this product deletes children's personal information if collected without parental consent.
- Parental consent notice and method for submission are provided.
Is the product intended for school?
- Unclear whether intended for students.
- Unclear whether personal information or education records are collected from preK-12 students.
- Unclear whether intended for teachers.
- Unclear whether this product is primarily used by, designed for, and marketed toward students in grades preK–12.
- Processes to enter education records into the product are not described.
- Unclear whether additional rights or protections may be provided with an additional school contract.
- Unclear whether the company is designated as a school official.
- Unclear whether this product transfers parental consent obligations to the school or district.
Can I control the use of my data?
- Users can control the use of their information through privacy settings.
- Use of information is limited to the purpose for which it was collected.
- The context or purpose for which data are collected is indicated.
- Company may combine data with additional data from third-party sources.
- Combined information is treated as personally identifiable information (PII).
- Notice is provided if the context in which data are collected changes.
- Consent is obtained if the practices in which data are collected change.
- A grievance or remedy mechanism is available for users to file a complaint.
- Users can request to know what personal information has been shared with third parties.
- Notice is provided in the event the company receives a government or legal request for a user's information.