Just when you thought you could take the blue pill.
Google Scholar works via algorithm. It examines papers that are hosted in certain domains (usually, publishers and higher education institutions) and then constructs citations based on those papers. As it is easily accessible and also includes citations from unpublished papers, Google Scholar is becoming increasingly popular as a key metric for academic performance.
It is an interesting question as to whether we should expect Google to be so hands off. After all, they are in the information retrieval business and if the information is being compromised, it would be in their interests to do something about it. And one can imagine certain correlations with published citations might yield some results. In the meantime, faculty at tenure-review or promotion time should have their citations examined under closer scrutiny.