Life With GDPR: Cathay Pacific Enforcement Action
Life With GDPR: Episode 30- British Airways Data Breach Enforcement Action
E18: ICANN Loses First GDPR Court Ruling in Germany
The UK ICO has provided guidance for employers on responding to employee subject access requests. Although much of the content reflects existing guidance, it deals specifically with issues such as requests made in the context...more
While countries all over the globe continue to make data privacy strides, comparing similarities and differences between the EU and U.K. is important in light of Brexit. It is also crucial to know the differences as they...more
Areas of interest include anonymisation, “recognised legitimate interests”, and the ICO’s role. The UK Data Protection and Digital Information Bill (the Bill) sets out the government’s proposals for reforming the current...more
In February 2022, the United Kingdom (UK) Information Commissioner’s Office (“ICO”), along with the data protection authority (“DPA”) in the UK, published three new documents ("UK Documents") which update the UK's position on...more
As the UK looks to find a new and post-Brexit direction, the UK Government is setting its agenda for developments in regulation, particularly when it comes to technology, data and innovation. We have seen the recent...more
The dust has settled on the new EU standard contractual clauses for cross-border data transfers (“New SCCs”), but confusion still reins on how the New SCCs cover data transfers and what companies need to do to take advantage...more
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
Companies have three months to prepare to use the latest standard contractual clauses for new data transfers, and 18 months to migrate existing arrangements. On 4 June 2021, the European Commission released its...more
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
With the UK unambiguously out of the EU, this fourth and final installment of our Data & Brexit Digest explores the topic of appointed representatives under Article 27. What is an Article 27 representative? The...more
On December 17, 2020, the UK Information Commissioner’s Office (‘ICO’) published its Data Sharing Code of Practice (the ‘Code’) following a public consultation which commenced in 2019. The Code focuses mainly on data sharing...more
Recent M&A deals the teams have worked on involving insolvent corporates have highlighted the challenges which exist around the transfer of customer lists and databases, which are often a significant asset for the buyer. ...more
Today (July 16) Europe’s highest court, the Court of Justice of the European Union (CJEU), in the case of Data Protection Commissioner v Facebook Ireland and Maximillian Schrems (Schrems II) invalidated the EU–U.S. Privacy...more
The Information Commissioner's Office (ICO) has issued a statement confirming that data protection will not stop the need for businesses to share information quickly, or adapt the way they work to face the unprecedented...more
BREXIT: DEAL OR NO-DEAL? DATA IS THE QUESTION - With the Brexit deadline looming ahead on 31 October 2019, the situation seemingly reaches new levels of uncertainty every day. Last week, the U.K. Supreme Court’s eleven...more
The United Kingdom’s Information Commissioners Office (ICO) has issued, for public consultation, draft guidelines for data sharing that—once adopted —will govern all controller-to-controller data sharing agreements which are...more
Questions to ask when sharing data between two data controllers (from the ICO Data Sharing Code of Conduct): What is the sharing meant to achieve?...more
Checklist for drafting your controller-controller data sharing agreement (from the ICO Data Sharing Code of Conduct now out for public consultation): What is the purpose of the data sharing initiative?...more
The UK Information Commissioner’s Office (ICO) has issued a new guidance on the liabilities of Controllers and Processors, advising that the Controller is responsible for assessing that its Processor is competent to process...more
A data subject (defined in the GDPR as an identified or identifiable natural person) has a right under the General Data Protection Regulation (GDPR) to make a data subject access request (DSAR) to find out what personal data...more
The European Union's General Data Protection Regulation ("GDPR") is arguably the most comprehensive - and complex - data privacy regulation in the world. Although the GDPR went into force on May 25, 2018, there continues to...more
Article 30 of the General Data Protection Regulation (GDPR), which comes into force on 25 May 2018, places an obligation upon data controllers and processors to keep internal records of data processing activities. The data...more
Those of us who have been grappling with how best to approach GDPR compliance in outsourcing and other commercial contracts will be all too familiar with Article 28 of the GDPR, which sets out a number of minimum contract...more
Although the EU General Data Protection Regulation comes into force in May 2018, European regulators are still producing guidance and member states are still adopting legislation to accommodate national differences. Put...more