The stakes are high for FemTech – as Benjamin Franklin noted: ‘it takes many good deeds to build a good reputation and only one bad one to lose it.’...more
7/19/2024
/ Consumer Privacy Rights ,
Data Protection ,
Data Protection Impact Assessments (DPIAs) ,
EU ,
Mobile Health Apps ,
Patient Privacy Rights ,
Personal Data ,
Regulatory Requirements ,
Risk Management ,
Sensitive Personal Information ,
Technology Sector ,
UK
Security, scale or functionality – pick two. This computer science principle coined by the late Professor Anderson is particularly relevant to the FemTech industry. Anderson’s Rule states that for a system to provide high...more
5/17/2024
/ Business Strategies ,
Digital Health ,
EU ,
General Data Protection Regulation (GDPR) ,
Health Care Providers ,
Health Insurance Portability and Accountability Act (HIPAA) ,
Health Technology ,
Innovation ,
Life Sciences ,
Med Tech ,
Popular ,
UK
In part one of our series "FemTech: how this growing industry can build trust, protect privacy and redress healthcare inequity… one app at a time", we take an introductory look at the industry, and offer some...more
3/11/2024
/ Data Privacy ,
Data Security ,
Data-Sharing ,
Health Care Providers ,
Information Commissioner's Office (ICO) ,
Mobile Health Apps ,
Personal Data ,
Personalized Medicine ,
PHI ,
Privacy Laws ,
Reproductive Healthcare Issues ,
UK
On 12 October the UK–U.S. “data bridge” becomes operational, providing an additional, compliant route for UK-outbound transfers of personal data to U.S. organisations that are EU-U.S. Data Privacy Framework members. UK...more
10/12/2023
/ Adequacy Requirement ,
Biden Administration ,
Data Protection ,
Data Subjects Rights ,
Executive Orders ,
Federal Trade Commission (FTC) ,
International Data Transfers ,
Personal Data ,
Popular ,
Privacy Framework ,
Regulatory Oversight ,
UK
On 18 August 2023, the UK’s Information Commissioner’s Office (“ICO”) published draft guidance on biometric recognition (the “Draft Guidance”) for public consultation. The Draft Guidance explains how data protection law...more
9/11/2023
/ Artificial Intelligence ,
Biometric Information ,
Consultation ,
Data Protection ,
Data Protection Impact Assessments (DPIAs) ,
Draft Guidance ,
Personal Data ,
Privacy-By-Design ,
UK ,
UK GDPR ,
UK ICO
The FCA is continuing to crack down on firms and ‘finfluencers’ using social media for non-compliant and illegal financial promotions and this week has announced plans to update its existing guidance on social media and...more
How should artificial intelligence (“AI”) be governed? This conundrum is rightly receiving considerable attention from governments, businesses and civil society. ...more
Artificial intelligence (“AI”), once limited to the pages of science fiction novels, is now viewed as a key strategic priority for both the UK and EU.
The UK, in particular, plays a prominent role at the cutting edge of...more
On 8 March 2023, the newly-created Department for Science, Innovation and Technology (“DSIT”) introduced the UK government’s updated proposals for data protection reform in the shape of the Data Protection and Digital...more
4/12/2023
/ Compliance ,
Consent ,
Cookies ,
Data Controller ,
Data Processors ,
Data Protection ,
Data Protection Officers (DPOs) ,
General Data Protection Regulation (GDPR) ,
Proposed Legislation ,
Regulatory Requirements ,
Small and Medium-Sized Enterprises (SMEs) ,
UK
On 18 January 2023, the European Data Protection Board (the “EDPB”) announced the adoption of a report on the work undertaken by the Cookie Banner Task Force (the “Task Force”). The Task Force was formed in September 2021 for...more
2/9/2023
/ Consent ,
Cookie Banners ,
Cookies ,
e-Privacy Directive ,
EU ,
EU Data Protection Laws ,
European Data Protection Board (EDPB) ,
General Data Protection Regulation (GDPR) ,
Information Commissioner's Office (ICO) ,
NGOs ,
Schrems I & Schrems II ,
UK
Though perhaps falling short of being a universally accepted one, it is a truth that any organisation processing personal data needs a privacy programme. But how best should an internal compliance framework be structured...more
The UK government confirmed on 30 November 2022 that there will be changes to the UK’s cybersecurity regulations in response to a public consultation launched earlier this year. This follows recent updates relating to the...more
12/30/2022
/ Compliance ,
Consultation ,
Cyber Attacks ,
Cyber Incident Reporting ,
Cybersecurity ,
Data Protection ,
Data Security ,
EU ,
EU Directive ,
Information Technology ,
Outsourcing ,
Popular ,
Proposed Amendments ,
Proposed Regulation ,
Third-Party Service Provider ,
UK
Over the past few years there has been significant growth in the use of technology for monitoring workers, especially following the onset of the COVID-19 pandemic. Global demand (based on the number of internet searches...more
11/4/2022
/ CCTV ,
CNIL ,
Consultation ,
Data Protection Impact Assessments (DPIAs) ,
Electronic Communications ,
Employee Monitoring ,
Employee Privacy Rights ,
Employment Policies ,
General Data Protection Regulation (GDPR) ,
Information Commissioner's Office (ICO) ,
UK
With the 27 December 2022 deadline for updating data transfer contracts with the EU SCCs fast approaching, this alert mines European Commission guidance, as well as the team’s experience, and offers some tips for successful...more
The Age Appropriate Design Code (“AADC”) - more commonly known as the Children’s Code - has been heralded as the world’s first code to protect children online. Compliance with the AADC became mandatory for in-scope businesses...more
In a joint letter this summer, the UK’s data protection regulator (the ICO) and the UK’s National Cyber Security Centre (the NCSC) sought to convey some key messages to the legal profession relevant to advising clients...more
8/22/2022
/ Australia ,
Client Services ,
Corporate Counsel ,
Cybersecurity ,
Cybersecurity Information Sharing Act (CISA) ,
Data Protection Authority ,
ENISA ,
FBI ,
Information Commissioner's Office (ICO) ,
NCSC ,
Popular ,
Ransomware ,
Reporting Requirements ,
Risk Mitigation ,
UK ,
UK GDPR
The UK government set out its detailed proposals for data protection reform on 18 July 2022 in the form of the Data Protection and Digital Information Bill. Compared with some of the radical ideas in the 2021 public...more
7/26/2022
/ Anonymization ,
Compliance ,
Consultation ,
Data Controller ,
Data Processors ,
Data Protection ,
Data Protection Authority ,
Data Subject Access Requests ,
EU Data Protection Laws ,
Proposed Legislation ,
UK
On 27 April 2022, the Russia (Sanctions) (EU Exit) (Amendment) (No 9) Regulations 2022, SI 2022/477 (the ‘Regulations’) were laid before Parliament and came into force two days later. The regime created under the statutory...more
Since the Schrems II 2020 judgment famously “cancelled” the EU/U.S. Privacy Shield program for personal data flows from the EU to the United States, it would be an understatement to say that U.S.-bound personal data flows...more
On 28 January 2022 (Data Protection Day), the UK’s International Data Transfer Agreement (“IDTA”) and International Data Transfer Addendum to the European Commission’s Standard Contractual Clauses (the “EU Addendum”) were...more
On 11 August, the UK Information Commissioner’s Office launched a consultation paper on “International transfers under UK GDPR”. The documents released alongside the paper include a draft International Data Transfer Agreement...more
8/16/2021
/ Consultation ,
Corporate Counsel ,
EU ,
European Commission ,
General Data Protection Regulation (GDPR) ,
Information Commissioner's Office (ICO) ,
International Data Transfers ,
Personal Data ,
Risk Assessment ,
Schrems I & Schrems II ,
Standard Contractual Clauses ,
UK
The European Commission recently adopted new standard contractual clauses (SCCs) for transfers of personal data from the EU to “third countries” (the “new SCCs”). In this post, we highlight key developments in the UK’s data...more
7/9/2021
/ Data Controller ,
Data Processors ,
EU ,
General Data Protection Regulation (GDPR) ,
Information Commissioner's Office (ICO) ,
International Data Transfers ,
Member State ,
Personal Data ,
Standard Contractual Clauses ,
UK ,
UK Brexit
On 28 June, the European Commission adopted its Adequacy Decision for the UK, putting to an end (at least for now), the uncertainty surrounding EU to UK personal data flows. This averted a “cliff edge” in the shape of the 30...more
The European Commission published a draft Adequacy Decision for the UK on 19 February. That document remains in draft, though it is understood to have successfully cleared the last formal approval stage required....more
6/21/2021
/ Adequacy Requirement ,
Data Protection ,
EU ,
European Commission ,
European Data Protection Board (EDPB) ,
General Data Protection Regulation (GDPR) ,
International Data Transfers ,
Member State ,
Personal Data ,
Standard Contractual Clauses ,
UK
This article explores the topic of appointed representatives under Article 27 of the GDPR. What are they? When do you need one? How is regulatory enforcement starting to play out in the EU and in the UK on this issue?...more
6/21/2021
/ Appointed Public Officials ,
Data Controller ,
Data Processors ,
Data Protection ,
Data Protection Authority ,
Enforcement Authority ,
EU ,
General Data Protection Regulation (GDPR) ,
Information Commissioner's Office (ICO) ,
Registered Representatives ,
Regulatory Requirements ,
UK