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Nothing like a last minute extra – just stepped in to moderate a great discussion with the excellent Herke Kranenborg and Yann Padova after their two co-speakers were unfortunately prevented from attending the CEDPO Conference (no, it wasn’t meant to be a “manel”). Great exchanges on the pragmatism and complications of the SRB judgment of […]
SRB: Do potential cyber attacks matter when assessing whether pseudonymisation is sufficient to make personal data cease to be “personal” from the perspective of a recipient? Short answer: no, they shouldn’t. Why is that? In my extensive analysis of the SRB judgment and its practical implications ( https://lnkd.in/e2eNmGUP ), I did not write much about […]
Significant news from the ICO re Meta: lower price than EU, and no “less personalised ads” offering… in the UK. The “Pay or OK” type of approach is alive and well over there (in this case: for Facebook & Instagram). Compared to the EU approach, it looks like the UK regulator has taken a pragmatic stance […]
Good to read about the EDPB promoting pseudonymisation in Seoul, but let’s be honest: their guidelines on the topic need serious updating further to the CJEU’s SRB judgment. Yes, they do say the opposite of SRB: 22. Pseudonymised data, which could be attributed to a natural person by the use of additional information, is to […]
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 […]
Interestingly mixed reactions to the CJEU’s SRB ruling. Some: “nothing new!”. Others: “finally, relative nature of personal data confirmed!”. Why? The Court stated in unambiguous terms (paras. 77 + 86) that pseudonymised data can be non-personal data for a recipient if the technical and organisational measures of the pseudonymisation are effective and prevent access by […]
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 […]
The Irish Data Protection Commission’s statement of 21 May 2025 “on Meta AI” (just like the judgment coming today in a German court case) provides a great excuse to talk briefly about GDPR legal grounds & AI model training, while I continue to work on the next part of my Better Regulation series (that next […]
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 […]
