Can't find what you're looking for? Try the search bar or refine your parameters using the Frameworks & Concepts button above.
Another week, another product announcement from someone involving AI in your pocket, on your wrist, in front of your eyes. I have met people whose lives have literally been transformed as a result of some of these tools, such as an individual who is suddenly able to use a camera in glasses to film his […]
Biometrics & Digital Omnibus: EU Council’s draft compromise could cripple biometrics in *all* industries if unchanged. The use of biometrics for identity verification is often based on consent (Art. 9(2)(a) GDPR), and the Commission’s proposal added a consent exemption if “the biometric data or the means needed for the [identity] verification is under the sole […]
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*, […]
What is “political advertising” – or not? And when is it permitted? Scope creep beyond legislative intent is a real danger, a risk *everyone* should care about (even if you don’t think political ads concern you). The descriptively named “EU Regulation on Transparency and Targeting of Political Advertising” (“TTPA” for short) has two key aims: […]
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 […]
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 […]
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 […]
In law, the choice of words matters, and a given interpretation can mean the difference between a behaviour being permitted or prohibited. When some recently claimed that the Cologne Higher Regional Court might have misinterpreted one of the European Union’s newer data-related acts, the Digital Markets Act (DMA for short), the challenge to the judges’ […]
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 […]
