Cynthia O'Donoghue

Cynthia O'Donoghue

Reed Smith

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EU antitrust authorities to take value of personal data into consideration when reviewing digital markets in merger and antitrust...

In an interview on 9 April 2015, European Competition Commissioner Margrethe Vestager indicated that companies who control personal data could come under increased scrutiny from European antitrust authorities. She recognises...more

4/16/2015 - Antitrust Division Big Data Data Controller EU Strategic Enforcement Plan

South Korea Strengthens Security Measures for Personal Information

South Korea’s Ministry of Government Administration and Home Affairs issued an amended version of the Standards of Personal Information Security Measures (the ‘Standards’). These Standards seek to close loopholes and...more

4/9/2015 - Cybersecurity Data Protection Mobile Devices Popular South Korea

Italy Releases Draft Declaration of Internet Rights

Italy’s Chamber of Deputies has proposed a ‘Draft Declaration of Internet Rights’ (Declaration), acknowledging both the way in which the internet has changed interactions and the way it has erased borders, but also noting...more

4/1/2015 - Declaration EU EU Data Protection Laws Italy

Enforced subject access requests now a criminal offence in the UK

In September 2014 we reported on the UK’s intention to stamp out a practice commonly known as “enforced subject access requests”. This concerned the previously dormant section 56 of the UK Data Protection Act 1998 (‘DPA’),...more

3/19/2015 - Criminal Background Checks Criminal Prosecution Subject Access Request UK

Ofgem's Smart Meter Network Decision: UK gas and electricity consumer privacy gets broader protection

In February 2015, Ofgem (the UK’s Office of Gas and Electricity Markets) published its Decision on Extending the Smart Meter Framework to Remote Meters (the Decision). This confirms that, following a public consultation, the...more

3/11/2015 - Climate Change Ofgem Oil & Gas Privacy Laws Smart Meters UK

FCA publishes Memorandum of Understanding between the FCA and ICO

On 28 January 2015, the Financial Conduct Authority (FCA) published the Memorandum of Understanding (MoU) which it entered into with the Information Commissioner’s Office (ICO) (dated 29 September 2014)....more

3/6/2015 - Financial Conduct Authority FSMA ICO Information Sharing Memorandum of Understanding

NGOs may rely on UK's Journalism Exemption

The UK Information Commissioner’s Officer (the “ICO”), in a letter to Global Witness (in Steinmetz and others v Global Witness) (the “Letter”), stated that non-media organisations may rely on the special-purposes exemption...more

3/6/2015 - Exemptions Journalism NGOs UK UK Data Protection Act

PCI Security Standards Council Announces Revisions to the use of SSL

The Payment Card Industry (PCI) Security Standards Council has released a bulletin on impending revisions to version 3.0 Payment Application Data Security Standards (PA-DSS) and version 3.0 of the PCI Data Security Standard...more

3/6/2015 - Cybersecurity Debit and Credit Card Transactions NIST PCI-DSS Standard Personally Identifiable Information

Article 29 Working Party issues its Cookie Sweep Combined Analysis - Report

On 3 February, the Article 29 Data Protection Working Party published its ‘Cookie Sweep Combined Analysis – Report’. The sweep was undertaken by the WP29 in partnership with eight of the European data protection regulators,...more

2/27/2015 - Cookies Data Collection EU Internet Media Right to Privacy Websites

South Korean Communications Commission Releases Guidelines on Data Protection for Big Data

In December 2014, the Korea Communications Commission (KCC) released the“Big Data Guidelines for Data Protection” (Guidelines). Aimed at Information and Communications Service Providers (ICSPs), they are designed to prevent...more

2/24/2015 - Big Data Data Breach Data Protection Personally Identifiable Information Privacy Policy South Korea

China's State Administration for Industry and Commerce Releases Measures Defining Consumer Personal Information

In January, China’s State Administration for Industry and Commerce (SAIC) released its ‘Measures on Penalties for Infringing Upon the Rights and Interests of Consumers’ (Measures) which are due to take effect March 15, 2015....more

2/24/2015 - China Data Collection Data Protection Personally Identifiable Information SAIC

Google signs UK Undertaking to Improve its Privacy Policy

On 30 January 2015, Google signed an Undertaking with the Information Commissioner’s Office (ICO) to improve and amend the Privacy Policy it adopted 1 March 2012....more

2/23/2015 - Big Data Data Collection Data-Sharing EU Google ICO Personally Identifiable Information Popular Privacy Policy UK YouTube

New Data Protection Laws in Africa

In recent years, the number of African countries which have enacted privacy frameworks or are planning data protection laws has vastly increased....more

2/23/2015 - Africa Cybersecurity Data Protection

EU Art. 29 Working Party Letter on Health Data and Apps

The EU Article 29 Working Party (“WP29”) has published a letter to the European Commission (“EC”) on the scope of health data in relation to lifestyle and well-being apps, following the EC’s Working Document on mHealth and...more

2/23/2015 - Consent Cybersecurity Data Collection Data Protection Digital Health EU European Commission mHealth Mobile Apps Popular Prior Express Consent

German Data Protection Commissioners Take Action Against Safe Harbor

At the Data Protection Conference in Berlin, the Berlin and Hamburg Data Protection Commissioners (Commissioners) made a number of important announcements regarding the ‘inadequacy’ of the EU/U.S. Safe Harbor Program. ...more

2/20/2015 - Cybersecurity Data Protection EU Germany Safe Harbors

Ofcom Publishes Plan To Support the Internet of Things

In January, Ofcom, the UK telecommunications regulator, published its Statement on ‘Promoting investment and innovation in the Internet of Things’ (Statement). The Statement acknowledges that the Internet of Things (IoT) has...more

2/19/2015 - Internet of Things OFCOM UK

Finland Introduces New Information Society Code

The Information Society Code (2014/917) (Code) – a new act in Finland on electronic communications, privacy, data security, communications, and the information society in general – took effect 1 January....more

2/16/2015

Australian Data Protection Authority Issues Guidelines On Securing Personal Information

On 19 January 2015, the Australian data protection authority, the Office of the Australian Information Commissioner (OAIC), released an updated information security guide: ‘Guide to securing personal information.' The Guide...more

2/10/2015 - Australian Privacy Principles Cybersecurity Data Protection

European Banking Authority Releases Internet Payment Guidelines

The European Banking Authority (EBA) released ‘Final guidelines on the security of internet payments’ (Guidelines). These Guidelines are based on the work published by the European Forum on the Security of Retail Payments...more

1/28/2015 - EU European Banking Authority Final Rules Internet Payments

EU Art. 29 Working Party Opinion on the Internet of Things

The EU Article 29 Working Party (WP29) has issued an Opinion on ‘Recent Developments on the Internet of Things’ (Opinion). The Opinion stresses the privacy and security challenges generated by the development of the Internet...more

1/21/2015 - Article 29 Working Group EU Internet of Things

EDPS publishes Guidelines on data protection in EU financial services regulation

The European Data Protection Supervisor published ‘Guidelines on data protection in EU financial services regulation’ (Guidelines) to be used as a “practical toolkit for ensuring that EU data protection rules are integrated...more

1/21/2015 - Consumer Financial Products Data Protection Authority EU EU Data Protection Laws Financial Institutions New Guidance

Turkish Parliament Approves E-Commerce Law

Turkey’s Parliament has approved Law No. 6563 on the Regulation of Electronic Commerce (Law) aimed at creating a more secure, transparent and accessible e-commerce environment. The Law is expected to come into force 1 May...more

1/21/2015 - E-Commerce New Legislation Turkey

EU Art. 29 Assesses Cybercrime Assessment

The Article 29 Data Protection Working Party (Working Party) sent a letter to the Council of Europe discussing its first assessment of several cybercrime scenarios presented at the 2014 Cybercrime@Octopus conference...more

1/21/2015 - Article 29 Working Group Cyber Crimes Cybersecurity EU

Dutch Data Protection Authority Threatens Google with a €15 million fine

The Dutch data protection authority, College Bescherming Persoonsgegevens (CBP), released a cease and desist order requiring Google to pay €60,000 per day, up to a maximum of €15 million, for violating Dutch data protection...more

1/21/2015 - Belgium Cease and Desist Data Protection Authority EU Data Protection Laws Google

European Commission and EU Art 29 dispel the myths on the ECJ's decision in Google Spain

In May 2014, we reported on the implications of the landmark decision in Google Spain which recognises the right for individuals to have links about themselves de-listed from search results. In response to the complaints...more

1/21/2015 - EU European Commission European Court of Justice Google Right to Be Forgotten

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