This provision grants advertisers the right to conduct or commission audits of Google's processing of advertiser personal data, subject to reasonable prior notice and scheduling during normal business hours.
This analysis describes what Google Ads's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
This clause satisfies the GDPR Article 28(3)(h) requirement that processor agreements include an audit right. The practical scope and logistics of exercising this right against a large cloud and advertising infrastructure provider may be operationally complex, and advertisers typically rely on third-party audit certifications such as ISO 27001 or SOC 2 reports as a practical substitute.
Interpretive note: The practical modalities of audit exercise, including whether direct inspection is operationally available or whether Google substitutes third-party certifications in practice, are not fully specified in the clause text available.
Under this clause, advertisers have the right to audit Google's processing activities for advertiser personal data. This provision supports the advertiser's ability to demonstrate compliance with GDPR Article 28 requirements to supervisory authorities.
How other platforms handle this
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Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will: Delete your personal information from our records; and Direct any service providers and contractors to delete your personal information from their records. Correct inaccurate personal information that ...
You may have certain rights regarding your personal information, depending on the state in which you reside. These rights may include: the right to know what personal information we have collected, used, disclosed, or sold; the right to delete personal information we have collected from you; the rig...
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"Google will allow for and contribute to audits, including inspections, conducted by the Customer or an auditor mandated by the Customer in relation to the processing of Customer Personal Data by Google, provided that Customer gives reasonable prior notice to Google and any audit is conducted during Google's normal business hours.— Excerpt from Google Ads's Google Ads Data Processing Terms
1) REGULATORY LANDSCAPE: This provision directly implements the GDPR Article 28(3)(h) audit and inspection right that processor agreements must include. The obligation applies under EU GDPR and UK GDPR. Supervisory authorities may request evidence of audit rights exercise or third-party audit reports during investigations of the advertiser as data controller. 2) GOVERNANCE EXPOSURE: Low to Medium. In practice, Google and similar large processors typically offer third-party audit certifications (ISO 27001, SOC 2 Type II) as a practical mechanism for satisfying the audit right, which is an accepted approach under GDPR guidance. Advertisers should confirm whether Google's DPA specifies this alternative and whether the available certifications cover the specific processing activities relevant to Google Ads. 3) JURISDICTION FLAGS: EU and UK advertisers should ensure audit rights can be exercised or substituted with certifications that satisfy supervisory authority expectations in their home jurisdiction. Some EU supervisory authorities have taken positions on the adequacy of certification-based audit substitutes that may affect this assessment. 4) CONTRACT AND VENDOR IMPLICATIONS: Procurement teams should confirm what audit formats Google accepts, whether direct inspections are available or whether only certification reviews are permitted in practice, and whether the costs of audits are allocated in the agreement. The requirement for reasonable prior notice and normal business hours scheduling may limit the practical exercise of this right. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should document the basis on which Google's processing is audited, whether through direct inspection or review of third-party certifications, and retain that documentation as evidence of ongoing vendor due diligence. This documentation may be requested by supervisory authorities during enforcement proceedings.
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This clause satisfies the GDPR Article 28(3)(h) requirement that processor agreements include an audit right. The practical scope and logistics of exercising this right against a large cloud and advertising infrastructure provider may be operationally complex, and advertisers typically rely on third-party audit certifications such as ISO 27001 or SOC 2 reports as a practical substitute.
Under this clause, advertisers have the right to audit Google's processing activities for advertiser personal data. This provision supports the advertiser's ability to demonstrate compliance with GDPR Article 28 requirements to supervisory authorities.
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