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It’s finally open: public consultation by the European Commission on the GDPR. Privacy campaigners will be sure to respond – but will controllers & processors? This is your chance to submit comments on what works and what doesn’t. Whether you see weaknesses in the way in which the DPO role is structured (I know this […]
Interesting new CJEU judgment on “controllership” (but only limited considerations re “joint controllership”) and perhaps incidentally broadening the legal ground of “legal obligation” under the GDPR. The CJEU says that legal provisions can determine the purposes and means “at least implicitly”, which is not exactly what some authorities had considered previously. The context: the Moniteur […]
Surely you don’t need consent to display a user interface? UIs illustrate issues re the EDPB’s strict ePrivacy guidelines, combined with a strict approach re consent exemptions. After all: – UIs are programming instructions (e.g. in HTML, CSS, Javascript in the case of websites) so that your browser / OS / … knows how to […]
Just over two weeks to go to comment on the extremely extensive ePrivacy guidelines of the EDPB, now covering pretty much any interaction with the Internet or a computer. Working on one anonymised response in particular to integrate concerns of certain organisations, I wonder once more why the EDPB did not seek to better justify […]
With the New Year comes a reminder that many companies update their contractual terms / privacy statements / etc. around this time – so keep track of what is happening. [A while ago I built a monitoring tool for one client to automatically keep them informed of updates (even small ones) to various legal documents […]
You probably don’t want to miss this! Tomorrow I have the pleasure of taking part in a roundtable on targeted advertising and “Pay or OK”, covering topics such as: – Regulatory developments affecting profile-based advertising – Legitimacy of targeted advertising as a business model – Subscription models (+ “pay or data”) as a valid compliance […]
Thanks Eduardo Ustaran for hosting and moderating this roundtable, where I will also have the pleasure of discussing “Pay or OK” and targeted advertising with Townsend FEEHAN (IAB Europe), Cecilia Alvarez (Meta), Miko?aj Barczentewicz (University of Surrey) and David Pfau (Conreri). Looking forward to this! gdpr data protection eprivacy
So consent will be needed for contextual ads? Why limit ourselves then?” Top 5 concerns and questions shared with me by various clients re new EDPB�ePrivacy�guidelines: 1. “Do they even understand the technology?”: Overbroad notion of “access” is regulatory activism at its worst, coupling active notion of “access” to passive receipt, conflating individual entering into […]
The relative nature of “personal data” strikes again (or does it?). In today’s judgment in C-319/22 (Scania), the CJEU has seemingly confirmed that whether information is “personal data” or not depends on the entity/person processing it, like the General Court had done in other cases. This case asks whether a vehicle identification number (VIN) is […]
Pro tip: next time you want to let an AI bot join a group call on your behalf, make sure that all participants are OK with it. (In recent calls within the digitalecosystem and adtech industry, it’s like every week we have to boot a new transcription bot that was invited by a different person […]