AI Agents – When agency and subordination go hand in hand

This is an article that I wrote in the context of a Chatham House rules roundtable on questions to be tackled more extensively in the future regarding the interaction between AI systems & data protection. This particular one relates to AI agents and the notion of authority, notably as regards (i) the user’s perspective (subordination?), […]

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Save the date for the exclusive data protection enforcement event in Belgium

In Belgium? Speak Dutch and French? Active in data protection? Mark 2 September in your agenda for an exclusive event regarding the Belgian DPA’s Litigation Chamber. More details soon, but it should be really fun, and I am honoured to be among the excellent panel of speakers! (Stay tuned – limited seating, and in an […]

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Challenging technical assumptions in data protection enforcement

Not a “what ABC taught me about privacy” thing, but a man held on for dear life to the seat in front of him as the plane banked (normally) on my flight back from a great conference in Vilnius. It did bring me back to what I had been telling the hundreds of attendees to […]

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Must a corporate controller reveal employee identities to data subjects?

That was fast – less than a week after a CJEU judgment stating that it may be necessary for a controller to reveal the identity of the persons (e.g. employees) who processed personal data (C-579/21), the Belgian DPA applies that reasoning (in a separate case from the one handled by the CJEU) and orders a […]

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Digital Fairness Act: balancing enforcement and consumer reality

Key takeaways from a great lunch discussion on the Digital Fairness Act with European Commission officials and representatives from consumer rights / industry / SME organisations: – Businesses of all sizes should start gathering data to show to the Commission the impact that personalised advertising has had on their growth, if applicable. – The Commission […]

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A curious settlement by the Belgian DPA over minor structural violations

Amusing settlement decision by the Belgian DPA published yesterday: 500 EUR & 250 EUR respectively, plus adaptations to policies and procedures, so that when people book a table in a given restaurant by phone their data isn’t included automatically in a third-party table booking system and then used to send commercial e-mails. The lesson? If […]

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Singapore’s new AI fairness toolkit highlights global governance trends

Today’s release of an artificialintelligence fairness toolkit (Veritas Toolkit v2.0) by the Monetary Authority of Singapore is an occasion to recall that there is no plug-and-play tool for everyone – but toolkits can be a useful source of inspiration. Released under an Apache 2.0 open source licence, the diagnosis tool (in Python) and assessment tool […]

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Analyzing a new data transfer challenge filed before the EU General Court

Interesting case filed before the EU General Court by a person represented by noyb.eu, now published in the EU Official Journal. The complainants (the applicant + noyb) had sought access to the European Data Protection Board’s file concerning the EDPB’s Facebook-related binding decision of 5 December 2022. The EDPB refused to grant access, “on the […]

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Processor obligations and the CJEU’s Scania judgment nuances

Reposting, as I disagree in part and think it’s a debate worth having. If someone acts as a processor under GDPR and processes information that the processor cannot lawfully link (or get linked) to an identifiable natural person but that is personal data from the perspective of the controller, the processing on behalf of the […]

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About AI training & legitimate interest as a GDPR legal ground

The Irish Data Protection Commission’s statement of 21 May 2025 “on Meta AI” (just like the judgment coming today in a German court case) provides a great excuse to talk briefly about GDPR legal grounds & AI model training, while I continue to work on the next part of my Better Regulation series (that next […]

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