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Not just a good excuse to brush up my limited German! Yesterday’s dual-language event in Zurich was an excellent blend of discussions regarding the concept of “personal data” and the tensions with data sharing frameworks. The juxtaposition of my opening keynote (in English) on case law on the notion of personal data (+ Digital Omnibus […]
As I was in a meeting when the European Data Protection Board opened registration for its pseudonymisation stakeholder event of 12 December 2025, I missed the short (approx. 1h) registration window and they placed me on a waiting list instead – a pity given my frequent interventions on the EU Court of Justice’s SRB judgment […]
The ruling of the Court of Justice of the European Union (CJEU) of yesterday, 4 September 2025, in the EDPS v SRB case is significant – never mind the naysayers. It is the first time that the CJUE has clearly, explicitly said that if a dataset initially contains personal data but is pseudonymised, and that […]
My takeaways from the 100+ comment discussion following my post on whether the Crowdstrike incident is a “personal data breach” under the GDPR: 1. There are clearly two camps on this. I didn’t expect this level of opposition between two visions of what is a personal data breach. 2. One camp adheres to the views […]
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 […]
Can GDPR administrative fines be imposed for infringements that are not the result of either intent or negligence? (e.g. excusable, non-negligent human error) The CJEU Advocate General Campos S�nchez-Bordona says “No”. Others have already reported on the consequences of the new Opinion in the Deutsche Wohnen case (C?807/21) from the perspective of whether an undertaking […]
Will data protection authorities be a top target for cybercriminals? Forced sharing of trade secrets is one of the consequences of yesterday’s CJEU judgment, in a way that in my view should prompt a serious question: how will organisations share those trade secrets with those supervisory authorities [SAs], and can the latter be trusted to […]
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 […]
Looking back + forwards, 4 big topics for me on LinkedIn in 2024 & likely still for 2025 are the following:– ePrivacy– “Consent or Pay”– AI & personal data– Cybersecurity The key ePrivacy topic was the European Data Protection Board’s guidelines on the technical scope of Art. 5(3) of the ePrivacy Directive – basically, “to […]
Newest Belgian DPA decision confirms that “data breach” is not always “GDPR infringement”, in a decision that (i) suggests good practices so that the data breach response does not itself become a GDPR infringement and (ii) echoes (without quoting) the CJEU’s cybersecurity judgment of 14 December 2023 (Natsionalna agentsia za prihodite). � Context: Further to […]
