Background On 28 May 2021, the Information Commissioner’s Office (“ICO“) published a call for views on the first draft chapter of its anonymisation, pseudonymisation and privacy enhancing technologies draft guidance). This first chapter is part of a series of chapters of guidance that the ICO will be publishing on anonymisation and pseudonymisation and their role … Read more

Key takeaways The European Union Commission released its long awaited proposed regulation of artificial intelligence on 21 April 2021 (see press release here), which sets out a risk-based approach to regulation designed to increase trust in the technology and ensure the safety of people and businesses above all. The regulation has extra-territorial scope meaning that … Read more

Executive Summary On 17 December 2020, the Information Commissioner’s Office (“ICO”) published a new Data Sharing Code of Practice (the “Code”). As nearly ten years have passed since the implementation of the previous data sharing code published by the ICO, the new Code has been updated to reflect key changes in data protection laws and … Read more

Some of the key changes to the Personal Data Protection Act 2012 (“PDPA”) took effect on 1 February 2021. These include a mandatory breach notification regime and new consent exceptions, including an exception which may apply if an organisation has legitimate interests in the collection, use or disclosure of the personal data and the legitimate … Read more

Summary The ICO (the UK privacy regulator) has updated its guidance on data subject access rights, and the revised guidance appears to be aimed at giving organisations practical advice on managing and responding to subject access requests by including further detail and examples. Although the revised guidance has not changed dramatically, it is fair to … Read more

The High Court has dismissed a Part 8 claim against a bank for allegedly failing to provide an adequate response to the claimant’s Data Subject Access Requests (DSARs). This is a noteworthy decision for financial institutions, particularly those with a strong retail customer base, as it highlights the robust approach that the court is willing … 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