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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 […]
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 […]
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 […]
Belgian DPA’s direct marketing recommendation: great first attempt, but questionable positions included. First thoughts: [The BDPA has published a new direct marketing recommendation (replacing one of 5 years ago), and it’s a very good document. A public consultation is open until 10 May, and I hope some comments will deal with its shortcomings.] – Claim […]
Yesterday, I had the pleasure of giving a 5h presentation on the latest case law on the GDPR and other data protection legislation at various levels (Belgium, other EU countries, the Court of Justice and the European Court of Human Rights) to Data Protection Officers from a broad range of organisations and companies. The past […]
One of the tidbits in the Belgian Data Protection Authority’s “Management Plan 2024”: “Setting a sanctions policy, taking the EDPB’s guidelines on fines into account” (action point for 2024 for the Litigation Chamber). Interestingly for the broader question of the legal value of EDPB guidelines, this sanctions policy is described elsewhere in the document as […]
The European Data Protection Board is at it again: an urgent procedure has been launched to obtain clarification on “some of the core issues that arise in the context of processing for the purpose of developing and training an AI model”. The aim? To bring “some much needed clarity into this complex area”. Yet the […]
No “reject all” button? Different colours in a cookie banner? Belgian DPA orders a change, based on “dark pattern” allegations and lack of freely given consent. Readers know I have my doubts on this, due because “in the physical world” we are led to make choices all the time based on product colours (some of […]
New Belgian DPA decision, interesting on 3 points: 1. Confirmation of BDPA’s approach re “legal obligation” and “public interest” legal grounds 2. Re retention: the need to assess recidivism does not justify unlimited processing 3. Reference to EDPB’s newly updated GDPR fining guidelines (re factors affecting the amount of the fine) 1. The Order of […]
Reading through the CNIL’s new decision against Yahoo on cookies brings back to mind a question that has stuck with me for well over a decade: what is the exact reasoning that has led many EU-based authorities to say that advertising cookies/etc. are not strictly necessary for the provision of a service, and why does […]
