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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 […]
When I pointed out issues with the DMA-GDPR Guidelines & resulting risks for *all* controllers (not just gatekeepers), the EDPB’s Gwendal Le Grand said something to the effect of “Don’t just post about it, submit a response”. So here we go, a copy of the response submitted yesterday to the public consultation by the Commission […]
GDPR & DMA at CEDPO: Another great discussion (and a mini bit of sparring too) with Gwendal Le Grand, together with Borja Martínez Corral and our moderator Natascha Gerlach. Readers know how often I get to write critically about the European Data Protection Board, and my first thoughts on their DMA-GDPR Guidelines drafted together with […]
Not a gatekeeper? No matter – the DMA-GDPR Guidelines of the EDPB & European Commission are important: the EDPB’s input aims to ensure consistency in the interpretation of the GDPR. I’ll go through all 55 pages before next week’s great CEDPO panel with the EDPB’s own Gwendal Le Grand, Borja Martínez Corral and our moderator […]
Fun day! After moderating a RAID panel with as panelists EDPB Chair Anu Talus, Luxembourg CNPD President Tine A. Larsen, Deputy Head of Data Protection Unit at the Commission’s DG Justice Karolina Mojzesowicz, MEP Brando Benifei and Gibson Dunn Partner Ahmed Baladi, I then was a speaker in a debate alongside Max Schrems of noyb.eu, […]
Does training of AI systems involve the processing of personal data, and is it permitted under the GDPR? These were the two fundamental questions that I have already looked into in two previous articles: On the date of that second article, the Cologne Higher Regional Court (the Oberlandesgericht Köln – the Cologne HRC) delivered a […]
Part 2 of critical review of the Commission’s PayorOK decision on Meta & the DMA: now for the more GDPR-related part, on consent. As mentioned in part 1 ( https://lnkd.in/dvNKkjWk ), the European Commission (EC) draws lots from the EDPB’s Consent or Pay Opinion. [I was *very* critical of that Opinion – see https://lnkd.in/eddQ4yW8 ] […]
Heated exchanges at our “Pay or OK” workshop yesterday at CPDP, in particular between Max Schrems, Peter Hense ???????? and Lex Zard on the one hand and Cecilia Alvarez, Dirk Auer and myself on the other hand, with Miko?aj Barczentewicz moderating and economic input from Garrett Johnson. Perhaps the overcrowded room without ventilation played its […]
The European Commission’s announcement that it will consider simplifying regulatory regimes, notably in relation to data and technology, seems to open Pandora’s box. Is it a chance to draw lessons from what works well and what works less well? In this series on “Better Regulation” in relation to the digital economy, I will be exploring […]
Great events I’ll have the pleasure of speaking at in May: 1?? First, an IAPP web conference on adtech where I will be speaking alongside Dr. Sachiko Scheuing (with Joe Jones as moderator). “Adtech: Practical takeaways from recent EU developments”, on 7 May 2024 (4-5pm CET; 10-11am Eastern US). Organised by the IAPP – International […]
