ICO OPENS CONSULTATION ON DATA SUBJECT ACCESS RIGHTS

The ICO (the UK privacy regulator) has published draft guidance on the right of individuals under the GDPR to access their data. Key takeaways include: An acknowledgement that subject access requests can be burdensome, with a requirement to ‘make extensive efforts’ to locate and retrieve information and confirmation that a significant burden does not make … Read more

EDPB Adopts Final Guidelines on GDPR Extra-territoriality

Almost exactly a year after publishing its draft version, the EDPB has adopted its final guidelines on Article 3 of the GDPR and the extra-territorial scope of the legislation. The adopted guidelines don’t differ substantially from the consultation draft but include a number of clarifications and new examples. Some of the key takeaways are: Article … Read more

Facial Recognition Technology and Data Protection Law: the ICO’s view

The Information Commissioner’s Office in the UK (ICO) has announced an investigation into the use of facial recognition technology following a string of high profile uses. Prior to the results of this investigation, companies using facial recognition technology should: undertake a balancing test to ensure proportionality in the use of such technology, acknowledging its intrusiveness; … Read more

The Encryption debate is far from ‘going dark’

Shortly after the release of the communiqué from the most recent ministerial meetings of the ‘Five Countries’ security alliance — Australia, Canada, New Zealand, the UK and the US — at the end of July, we warned that the issue of the use of, and access to, encrypted services and technologies ‘remains front of mind for … Read more

CALCULATION GUIDELINES ON GDPR FINES IN GERMANY

In our latest report, we informed you about new developments regarding imposed sanctions by Data Protection Authorities (“DPA”) in Germany and Austria and about a model for calculating fines imposed under the General Data Protection Regulation (“GDPR”) proposed by the Conference of the German “Independent Data Protection Supervisory Authorities of the Federal Government and the … Read more

Joint controller relationships – more prevalent than previously thought? Article published in Privacy and Data Protection Journal

The Privacy and Data Protection Journal has published an article by Duc Tran (Senior Associate) and Laura Adde (Associate) of our Digital TMT, Sourcing & Data and Cyber Security teams. The article examines the concept of “joint controllership” in light of recent case law and existing legislative guidance. Please click here to access the full … Read more

China’s first regulation on children’s online privacy

The Cyberspace Administration of China (CAC) has, for the first time, issued legislation dedicated to protecting child privacy online. The Regulation on Protection of Children’s Personal Information Online is due to take effect on 1 October 2019. Read more