The investigation into Google’s tracking practices began after the publication of a 2018 Associated Press article. In its investigation, the AP had found that “many Google services on Android devices and iPhones store your location data even if you’ve used a privacy setting that says it will prevent Google from doing so.” This happened despite assurances from Google that disabling location history would prevent its apps from tracking users.

The state attorneys general found that Google misled its users about its practices since at least 2014. Google materially benefited from its deception by utilising the data captured to drive its advertising business.

In addition to the $391.5m, the settlement requires Google to “significantly improve its location tracking disclosures and user controls”. Specifically Google will need to:

1. Show more location-related account information to users;
2. Surface key information about location tracking to users;
3. Give users detailed information about the location data being collected; and
4. Explain how the data collected is used.

All of this information is to be featured in a new “Location Technologies” Google webpage, which will be starting in 2023. This delay suggests that location tracking is deeply embedded in Google’s systems and not easy to restructure or modify. It also seems to imply that despite being in the regulatory cross-hairs since the publication of the AP article in 2018 many of Google’s underlying practices have remained largely unchanged.