France’s Data Protection Authority unveils its inspection targets for 2014

by DLA Piper

The French Data Protection Authority (the CNIL) has announced its 2014 inspection targets, with the goal of reaching 550 inspections for the year. Last year, the CNIL carried out 414 inspections.

Capitalizing on a March 2014 law that authorizes the CNIL to conduct remote, on-line inspections (see our blog post here
), the CNIL has announced that it intends to conduct 200 on-line inspections in 2014. The remaining 350 inspections will be on-site.

The authority will focus on on-line services, on-line payment, social media and data breach reporting by electronic communication service providers. The authority also participated on May 13, 2014 in the Internet Sweep Day initiative, this year focusing on mobile app privacy issues, in particular user privacy notices.

The specific priority areas for 2014 include:

  • Personal data gathering by online social networks. Of particular interest to the CNIL is the significant amount of personal data collected on social networks, including sensitive personal data such as sexual orientation, ethnic origin and religious belief.
  • Online payment processing, including anti-fraud measures and banking data retention. This is a significant source of complaints to the CNIL, and the inspections will verify compliance with the CNIL's November 2013 recommendation on the storage of credit card numbers (see our blog post here).
  • Management of personal data breaches by electronic communications service providers. Since 2011, such service providers must report breaches to the CNIL, and, in certain circumstances, to the individuals concerned.
  • The French national database of household credit repayment defaults. This database is the number one source of complaints in the lending sector.

International inspection operations

The CNIL also plans to again participate in Internet Sweep Day, first conducted in May 2013 by 20 data protection authorities to analyze privacy notices of some 2,000 websites worldwide. For 2014, Internet Sweep Day will be during the week of May 12 and will focus on mobile privacy.

The CNIL will also be involved in the Article 29 Working Party's review of cookies, which will provide an overview of European practices and harmonize the positions of different data protection authorities.

2013 inspections

Following the 414 inspections conducted by the CNIL in 2013, the CNIL issued a dozen cease–and-desist notices and in one instance even referred the case to the French Public Prosecutor. Almost a third of the 2013 inspections were related to video surveillance (134 inspections); the remaining were related to compliance with the French Data Protection Law.

The CNIL's inspections video surveillance systems highlighted persistent violations of French law regarding the use of such systems, and, notably, repeated failures to file a prior declaration with the CNIL or to obtain authorization from the Prefect. Other issues encountered by the CNIL relating to video surveillance include insufficient notice to persons filmed, and inadequate security measures.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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