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AI Act compliance is complex, so it’s good when tools can help you along the way. It was a privilege to develop such a tool for one client. There are plenty of amazing resources available to help organisations, such as (to name just a couple) a great tool by David Rosenthal of Visscher, fantastic infographics […]
Yes, the EU Data Act is now largely applicable, but what are the actual concerns and opportunities? In my discussions with various organisations, there has been one common fear: does this mean that I have to make all data concerning connected devices, including business-confidential information, available to everyone? The answer, as often in law, is […]
The ruling of the Court of Justice of the European Union (CJEU) of yesterday, 4 September 2025, in the EDPS v SRB case is significant – never mind the naysayers. It is the first time that the CJUE has clearly, explicitly said that if a dataset initially contains personal data but is pseudonymised, and that […]
My takeaways from the 100+ comment discussion following my post on whether the Crowdstrike incident is a “personal data breach” under the GDPR: 1. There are clearly two camps on this. I didn’t expect this level of opposition between two visions of what is a personal data breach. 2. One camp adheres to the views […]
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 […]
Better Regulation: Rethinking (or getting rid of?) the ePrivacy Directive” – going past the soundbites, this is a hard look at the ePrivacy rules and whether they should still exist today. Readers will know I have often criticised the European Data Protection Board’s views on Article 5(3) of the ePrivacy Directive (the “cookie” rule) because […]
The European Commission’s announcement that it will consider simplifying regulatory regimes, notably in relation to data and technology, seems to open Pandora’s box. Is it a chance to draw lessons from what works well and what works less well? In this series on “Better Regulation” in relation to the digital economy, I will be exploring […]
On this fifth GDPR anniversary, remember that data protection principles are increasingly serving as inspiration for legal obligations regarding the use of “non-personal”/”corporate” data. What was good business practice is becoming a statutory obligation. So double-check that you have everything you *should* have, because soon you will be *required* to have it. Not that privacy […]
Here are 15 lessons based on an analysis of various data protection authority decisions across Europe, from a GDPR and cybersecurity article I just submitted after a reputed information security journal reached out. Cybersecurity compliance beyond best practices: key lessons: 1) Document your risk assessments and decisions. => If you deviate from common best practices, […]
Can GDPR administrative fines be imposed for infringements that are not the result of either intent or negligence? (e.g. excusable, non-negligent human error) The CJEU Advocate General Campos S�nchez-Bordona says “No”. Others have already reported on the consequences of the new Opinion in the Deutsche Wohnen case (C?807/21) from the perspective of whether an undertaking […]
