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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 […]
Looking forward to seeing many contacts next week at the IAPP Congress in Brussels – let me know if you would like to meet up on the Wednesday or Thursday. On Tuesday 14 November we are giving an invite-only workshop to select companies on Tomorrow’s Data Challenges, with discussions on topics such as dark patterns, […]
I’m seeing significant misinterpretations of the CJEU’s newest GDPR judgment. The CJEU *did not say* today that simply seeing information on a mobile app is processing of personal data. Instead, it said that *the process by which a COVID certificate is scanned by a device and then interpreted to reveal a green checkmark or a […]
Fines aren’t the only possible sanction in case of an infringement of data protection rules – prison is also a possibility in certain countries. That’s exactly the outcome of a case in France, where a former head of HR received a six-month (suspended) prison sentence yesterday. In that case, the person in question had created […]
I’m not sure X/Y’s data protection practices are compliant” is not a justification for filing a complaint, says the Belgian DPA in a new decision, reminding data subjects that they should exercise their rights before a complaint or at least be able to show that an alleged non-compliance by a controller or processor somehow affects […]
Important comment by the Belgian Market Court in a new judgment, here on confidentiality of controller/processor documents vis-�-vis a complainant: “the general principle regarding the prohibition of the abuse of rights prevents a complainant [�] from using the complaint to obtain information that it would not be able to obtain lawfully by other means”. The […]
Great news about the EU-U.S. adequacy decision! But let’s remember that many organisations want a solution for global transfers, not just for the United States. While the EU-U.S. adequacy decision helps a lot, it is only part of the solution that organisations need. Let’s look at some of the other components. Another part of the […]
After some initial thoughts on Tuesday, here is a slightly expanded analysis of the “contract” legal ground assessment by the CJEU in its new Meta judgment (C-252/21). Once again, I hope this ruling will not be misapplied in practice – and that controllers who build personalisation into a service for valid reasons are not forced […]
Good reflexes regarding datagovernance and aigovernance, what to expect from the upcoming legislation and how to prepare, those were some of the topics discussed during our panel on the EU draft AIAct and the DataAct at the Flanders AI Forum 2023. A few additional thoughts: “Data/AI isn�t our core business�? Every business involves data & […]
The team is intellectually agile, energetic and always available. Our industry can be complicated to understand, due to fast-paced technology developments, and the technical background of the partner we work with facilitates a lot our interactions and significantly improves the quality of deliverables. “[…] pedagogy and ability to simplify has been crucial to boost communications […]