The European Court of Justice (“ECJ”) has today invalidated the EU-US Privacy Shield, meaning that companies can no longer rely on this mechanism for transferring personal data from the EU to the US. Companies transferring data to the US relying on the Privacy Shield (including transfers to a number of the big tech IT service … Read more

In a move that marks a major U-turn for the Government, the UK’s proposals for a centralised contact tracing app have been abandoned in favour of a decentralised model. The new model is based on technology developed by Apple and Google and replaces the original app designed by NHSX, which recently has faced criticism due … Read more

On 17 April 2020, the ICO published an opinion by the Information Commissioner (the “Commissioner”) on Apple and Google’s joint initiative to develop COVID-19 contact tracing technology (the “Opinion”, available here). Summary The Commissioner found the CTF to be aligned with principles of data protection by design and by default. Controllers designing contact tracing apps … Read more

The ICO has published details of its regulatory approach during the ongoing COVID-19 emergency; this is an approach which should reassure entities who are adapting to the economic and practical realities of operating in the current climate, as well as balancing their data protection obligations.  The UK regulator has continued to be reasonable and pragmatic, … Read more

Background The COVID-19 outbreak has resulted in an unprecedented focus on the power of data to assist in resolving national emergencies. From health tracking, to volunteer coordination, to accurately identifying the vulnerable, data is being harnessed in both the public and private sectors to try to help bring COVID-19 under control and mitigate its impact. Read more

Today the Supreme Court handed down its decision in Wm Morrisons Supermarkets Plc v Various Claimants [2020] UKSC 12, bringing to its conclusion a case which had the potential to alter significantly the data protection and cyber security litigation and class action landscape. The headline news is that Morrisons has been found not to be … Read more

The COVID-19 outbreak is proving an interesting time to be a data protection practitioner. There seems to be a new article each day about the next exciting app which promises to use data to help manage the crisis. This post focuses on two particular propositions that pose interesting data protection considerations. It also flags the … Read more

Given the COVID-19 crisis, it is likely that data protection may no longer at the forefront of every controller’s mind, and rather, that business continuity has taken precedence. Acknowledging this shift and the need for companies to divert business as usual resources to their response to the crisis, the ICO has published two articles on … Read more