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While I disagree with his conclusions, do read the post of Damien Desfontaines re the BfDI’s public consultation on personal data in AI models. Pity that it ends on 31 August, with the EU Court of Justice’s SRB judgment coming out on 4 September. I hope the BfDI takes a relativistic approach to the notion […]
A months-old German court decision on Google Tag Manager has resurfaced here, with many claiming the GDPR applies to every use of GTM or similar tools. A bit of nuance may be useful: – First, that claim that the use of IP addresses and other identifiers = always processing of personal data? Let’s first wait […]
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 […]
Reposting, as I disagree in part and think it’s a debate worth having. If someone acts as a processor under GDPR and processes information that the processor cannot lawfully link (or get linked) to an identifiable natural person but that is personal data from the perspective of the controller, the processing on behalf of the […]
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 […]
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 […]
Personal data is a relative concept, EU General Court stresses in a new judgment – “it is necessary to put oneself in [the relevant organisation’s] position in order to determine whether the information transmitted to it relates to �identifiable persons�. The judgment reaffirms the conditional findings of the CJEU in its Breyer judgment (which found […]
Readers will know that some of the EDPB’s positions in its pseudonymisation guidelines are unconvincing or absolutist by nature. Now, IAB Europe and other associations in the digital ecosystem have submitted their feedback on these guidelines, and the feedback shows the acute need for a review of those guidelines. This response is well worth the […]
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 […]
