In October 2012, following several months of investigation by the French data protection authority (CNIL) of the new confidentiality rules published by Google, the Article 29 Working Party (group of European data protection authorities) had made a series of recommendations. These recommendations had primarily sought to heighten the level of information given to users in relation to the data collected and the purposes for which data is collected, to change the data combination practices for data collected across Google’s various services, in particular by strengthening user consent and reinforcing user control options, and to introduce data retention periods.

Google having failed to respond to those recommendations or to take the necessary measures to comply therewith, the European regulators decided to pursue their investigations and set up a working group to coordinate enforcement action against the US company.