This provision requires Google to implement and maintain technical and organizational security measures to protect advertiser personal data against destruction, loss, alteration, unauthorized disclosure, or unauthorized access.
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 establishes Google's contractual security obligation for advertiser personal data processed through Google Ads services. The obligation mirrors the GDPR Article 32 requirement for appropriate technical and organizational measures, and the specific measures implemented may be documented in a security annex or exhibit to the agreement.
Interpretive note: The specific technical and organizational measures Google implements are not defined in the clause text itself; the adequacy assessment requires review of any security annex or linked documentation incorporated by reference.
Under this clause, personal data processed through Google Ads is subject to Google's stated technical and organizational security measures. The specific measures and their adequacy relative to the risk profile of the data processed are not defined in the clause itself.
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"Google will implement and maintain technical and organizational measures to protect Customer Personal Data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Customer Personal Data.— Excerpt from Google Ads's Google Ads Data Processing Terms
1) REGULATORY LANDSCAPE: This provision implements the processor security obligation under GDPR Article 32, which requires security measures appropriate to the risk of processing, including as appropriate encryption, pseudonymization, and ongoing testing of security systems. Enforcement authority rests with EU supervisory authorities. A data breach involving advertiser personal data processed by Google may trigger notification obligations for the advertiser as controller under GDPR Article 33 and Article 34. 2) GOVERNANCE EXPOSURE: Medium. The general nature of the security commitment means that advertisers cannot rely solely on this clause to demonstrate GDPR Article 32 compliance; they must evaluate the specific measures Google implements, typically described in a security measures annex or linked documentation. The adequacy of security measures relative to the specific data categories processed through Google Ads should be assessed. 3) JURISDICTION FLAGS: EU and UK advertisers bear independent controller obligations under GDPR Article 32 to ensure their processors provide sufficient security guarantees. Advertisers in regulated sectors such as financial services or healthcare may have sector-specific security requirements that exceed the general standard referenced in this clause. 4) CONTRACT AND VENDOR IMPLICATIONS: Procurement teams should obtain and review Google's specific security measures documentation, typically referenced as an annex to the DPA. Vendor risk assessments should evaluate whether Google's stated measures are appropriate to the data types and volumes processed through the advertiser's Google Ads implementation, including any sensitive categories of inferred data. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should document the security measures evaluation as part of the vendor due diligence record. Data breach response procedures should account for Google's processor breach notification obligations to the advertiser, and the advertiser's independent 72-hour notification obligation to supervisory authorities under GDPR Article 33 should be reflected in incident response plans.
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This clause establishes Google's contractual security obligation for advertiser personal data processed through Google Ads services. The obligation mirrors the GDPR Article 32 requirement for appropriate technical and organizational measures, and the specific measures implemented may be documented in a security annex or exhibit to the agreement.
Under this clause, personal data processed through Google Ads is subject to Google's stated technical and organizational security measures. The specific measures and their adequacy relative to the risk profile of the data processed are not defined in the clause itself.
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