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What does the EU Council’s draft Presidency compromise text on the GDPR & ePrivacy Digital Omnibus tell us? (1) The Council (for now) seems to recognise the need to clarify the concept of “personal data”. As a Recital 27a would provide: The identification of a natural person should be assessed *ex ante and in concreto*, […]
The clear repudiation of an “absolute” concept of personal data has thrown a sharp focus on the process of pseudonymisation in the world of data protection. Through its SRB judgment of 4 September 2025, the Court of Justice of the European Union (CJEU) made it clear that personal data that has undergone pseudonymisation can be […]
[This is a translation of an op-ed in French that was published in the French journal Revue Politique on SRB and the Digital Omnibus, plus the newest EDPB & EDPS Joint Opinion on the topic. The original in French can be found on the Revue Politique website. + The banner image is a jest – […]
Under which circumstances does the GDPR consider scientific research compatible with existing purposes of personal data processing? Recent positions by regulators and legislators show it is still a hot topic – one with major implications for R&D globally. Recital 159 of the GDPR states that “the processing of personal data for scientific research purposes should […]
Some thoughts (+ & -) on the EDPB & EDPS’s joint opinion on the GDPR & ePrivacy Digital Omnibus, part 1: + The overall tone seems constructive – On the definition of personal data (PD), I don’t think quoting the Scania/SRB situation of information being “indirectly” PD for a disclosing party (§16) helps the EDPB/EDPS’s […]
With the festive season upon us, I may be posting a little less and instead singing Christmas songs with the family. So let’s look back at 2025 and anticipate 2026, based on interactions with my LinkedIn articles & posts: – Pseudonymisation & the concept of “personal data” were significant in 2025. 4 of my top […]
From fishing (instead of the GDPR) to a random “v” having appeared instead of a few words (a typo upon deletion?), the Commission’s GDPR & Data Act Omnibus feels like a rushed document. But what does it cover really? I’m focussing here on GDPR & ePrivacy: – Personal data definition: I like the idea of […]
Key points from (& thoughts on) draft GDPR Digital Omnibus: First, Art. 4(1) GDPR would be completed with an SRB-like statement (great news), plus a mitigation of abusive interpretation of the Scania judgment (also great news). Art. 4(15) on “data concerning health” would also finally be more specific, avoiding some of the more awkward and […]
Significant news from the ICO re Meta: lower price than EU, and no “less personalised ads” offering… in the UK. The “Pay or OK” type of approach is alive and well over there (in this case: for Facebook & Instagram). Compared to the EU approach, it looks like the UK regulator has taken a pragmatic stance […]
The Irish Data Protection Commission’s statement of 21 May 2025 “on Meta AI” (just like the judgment coming today in a German court case) provides a great excuse to talk briefly about GDPR legal grounds & AI model training, while I continue to work on the next part of my Better Regulation series (that next […]
