Great to see the European Data Protection Board listening to feedback! For their next stakeholder event, the EDPB is giving time to people to register their interest in participating – and it might even consider making a distinction between active and passive participants (speakers vs observers). Don’t dismiss this one just because it’s about a […]
Podcast alert: Almost an hour, but lots of topics about the GDPR & ePrivacy Digital Omnibus in the launch episode of the ADPO’s podcast (Irish Association of DPOs) Thanks to Dr Maria Moloney & Gonzalo Caro for having me on their inaugural podcast! Topics include the importance of a dialogue, sensitive categories of personal data, […]
When do contracts have to be provided in response to a data subject access request? And should a controller maintain a copy thereof to enable data subject requests? A new Belgian DPA decision deals with this issue, applying the EU Court of Justice’s CRIF judgment to the issue of bank account contracts. Article 15 GDPR […]
The Irish DPC’s guide on accessing data on behalf of someone else remains relevant but incomplete. (It dates back to 2021 and has just been republished, in case anyone thought it sounded familiar.) It touches upon a very difficult issue – and one less clear-cut than the Irish DPC suggests. Yes, there are good reasons […]
This does not surprise me – as I was explaining yesterday to two podcast hosts, synthetic data is great on paper but it does not help with accuracy or real-life outliers/divergent situations. It’s easy to claim that synthetic data is the best way to comply with data minimisation and that “you don’t really need all […]
How a simple sentence in your privacy notice can restrict your digital marketing: the Belgian DPA issued an injunction to adapt digital marketing practices for a fitness club that had sent marketing e-mails to a club member, including for non-sporting events. The case highlights a classic misalignment between documentation and marketing practices, as well as […]
IAB Europe & TCF case: Belgian Market Court confirms Belgian DPA went too far in seeking enforcement of full range of measures against IAB Europe. Pleased to see the judgment of the Market Court/MC of Wednesday 7 January 2026, which set aside the BDPA’s decision of January 2023 (through which it had validated IAB Europe’s […]
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 […]
Appeal against Belgian DPA decision: important findings on legitimate interest, reasonable expectations and (non-)necessity of verifications of prior lawfulness. In a judgment of yesterday, the Market Court (Brussels Court of Appeal) lifted a reprimand for a company that had used personal data for marketing purposes. The legitimate interest considerations will be of great interest to […]
Podcast time again, with The Monopoly Report on the Digital Omnibus (focus on GDPR and ePrivacy changes). In this episode, Alan Chapell and I discuss the apparent intentions of the Commission, the link with case law of the EU Court of Justice, possible reactions from data protection regulators and more. Its publication this Wednesday ties […]