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Why is the “personal data” definition aspect of the Digital Omnibus deemed controversial by some? And why are the alleged issues with the definition in fact absent? The Commission’s proposal is to codify recent case law of the EU Court of Justice, notably the SRB judgment (4 Sept 2025), by putting it into the law […]
What does the EU Council’s draft Presidency compromise text on the GDPR & ePrivacy Digital Omnibus tell us? (1) The Council (for now) seems to recognise the need to clarify the concept of “personal data”. As a Recital 27a would provide: The identification of a natural person should be assessed *ex ante and in concreto*, […]
The clear repudiation of an “absolute” concept of personal data has thrown a sharp focus on the process of pseudonymisation in the world of data protection. Through its SRB judgment of 4 September 2025, the Court of Justice of the European Union (CJEU) made it clear that personal data that has undergone pseudonymisation can be […]
Is “personal data” an asset? A study on human dignity & data protection has been released that on paper sounds like it should cover all the key topics. Its authors argue that individuals are “the primary right-holders in relation to the processing of their personal data” and that these “are dignity-relevant manifestations of the person […]
Interesting study on where human dignity and data protection come together, worth the read. I’m not convinced by some parts, though, as there is too much room left for subjectivity in the way certain things are worded. The authors suggest 7 guiding principles, but of particular interest to me were their suggested 6 limits to […]
Some thoughts on the leaked EU Council draft compromise re the GDPR parts of the Digital Omnibus: – This draft reads as a major lobbying win by data protection authorities and civil society. The EDPB would be given more power, the Commission no supervision, and a lot of the more business-friendly proposals would be removed […]
[This is a translation of an op-ed in French that was published in the French journal Revue Politique on SRB and the Digital Omnibus, plus the newest EDPB & EDPS Joint Opinion on the topic. The original in French can be found on the Revue Politique website. + The banner image is a jest – […]
Very glad to see the EU Court of Justice confirm that EDPB binding decisions are challengeable, like the Advocate General had suggested beforehand. I commented the AG Opinion at the time, applauding it for its clear position in the topic. The CJEU’s reasoning is very similar to that of the AG: – “[the EDPB’s binding […]
Not just a good excuse to brush up my limited German! Yesterday’s dual-language event in Zurich was an excellent blend of discussions regarding the concept of “personal data” and the tensions with data sharing frameworks. The juxtaposition of my opening keynote (in English) on case law on the notion of personal data (+ Digital Omnibus […]
As I was in a meeting when the European Data Protection Board opened registration for its pseudonymisation stakeholder event of 12 December 2025, I missed the short (approx. 1h) registration window and they placed me on a waiting list instead – a pity given my frequent interventions on the EU Court of Justice’s SRB judgment […]
