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Some key findings from the responses to the DMA-GDPR Interplay consultation, now made public by the Commission & EDPB: – Quite a few civil society responses are copies of one another. Going through the submissions, you’ll see many with identical titles (“uncompromised privacy”, “ensuring data portability is practical and secure”, …) and content. Fortunately there […]
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 […]
On the Criteo decision of the French Conseil d’État: beyond the question of whether online identifiers are sufficient for identification (see below), this is a typical case of a court keeping fines 100% intact after questioning the scope of processing. It’s not the first time I have seen this: a court says “this isn’t all […]
[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 – […]
Pour les francophones: I was given the opportunity to write an op-ed for the French journal Revue Politique on SRB and the Digital Omnibus, plus the newest EDPB & EDPS Joint Opinion on the topic. The result? “Rendre le RGPD réaliste ? Les autorités ne le souhaitent qu’à moitié”. I’m working on a translation into […]
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 […]
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 […]
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 […]
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 […]
