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Key points from (& thoughts on) draft GDPR Digital Omnibus: First, Art. 4(1) GDPR would be completed with an SRB-like statement (great news), plus a mitigation of abusive interpretation of the Scania judgment (also great news). Art. 4(15) on “data concerning health” would also finally be more specific, avoiding some of the more awkward and […]
7 points after giving another in-depth presentation to global businesses on the path to NIS2 compliance (with a flavour of DORA and GDPR): (i) Having a broad enough team (“multidisciplinary” / “multi-stakeholder” / however you wish to call it) is not easy for many organisations, irrespective of their size (this is nothing new, but it […]
Looking back + forwards, 4 big topics for me on LinkedIn in 2024 & likely still for 2025 are the following:– ePrivacy– “Consent or Pay”– AI & personal data– Cybersecurity The key ePrivacy topic was the European Data Protection Board’s guidelines on the technical scope of Art. 5(3) of the ePrivacy Directive – basically, “to […]
Practical checklist: good practices for vendor/supplier risk management inspired by GDPR, NIS2, Data Governance Act and DORA. The underlying question: what good practices do these EU laws highlight and transform into legal obligations in certain cases, and how can we combine them? This checklist is *not* a comprehensive list of best practices, but it should […]