Google last March settled FTC charges it violated its own privacy policies when it launched the social network, Google Buzz.
CDD says users are still not sufficiently informed about the company's digital advertising and marketing practices, which it says are at the heart of the proposed changes, which take effect March 1.
There have been calls from Capitol Hill for a similar determination by the FTC.
As part of the FTC settlement, Google is barred from "misrepresenting the privacy or confidentiality of individuals' information or misrepresenting compliance with the U.S.-E.U Safe Harbor or other privacy, security, or compliance programs." It also requires Google to affirmatively obtain consent [opt in] "before sharing their information with third parties if Google changes its products or services in a way that results in information sharing that is contrary to any privacy promises made when the user's information was collected."
CDD says it has made informal inquiries and submissions, but is now making a formal request for an investigation, and asked the FTC to request that Google postpone the change until that investigation is complete.
In a blog posting, Google has outlined the ways it says web users will still have control over their Google surfing experience after the change, including editing or turning off their search history, setting Gmail chat to "off the record," using the "incognito" setting on Chrome or any of a series of privacy tools.