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How the GDPR interacts with AI models: my in-depth look at whether AI model training even involves the processing of “personal data”, and which legal grounds might be most appropriate even if we do consider that personal data is involved. With the European Data Protection Board’s “stakeholder” event registration opening tomorrow in relation to its […]
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 […]
Simplification and the Draghi report in relation to EU digital laws: what could/should be done? Some thoughts I shared at an event yesterday on the topic: 1. The laws themselves are not always bad. While I have argued for getting rid of the ePrivacy Directive altogether (by taking into account overlaps with the GDPR and […]
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 […]
Fun day! After moderating a RAID panel with as panelists EDPB Chair Anu Talus, Luxembourg CNPD President Tine A. Larsen, Deputy Head of Data Protection Unit at the Commission’s DG Justice Karolina Mojzesowicz, MEP Brando Benifei and Gibson Dunn Partner Ahmed Baladi, I then was a speaker in a debate alongside Max Schrems of noyb.eu, […]
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’ […]
My takeaways from the 100+ comment discussion following my post on whether the Crowdstrike incident is a “personal data breach” under the GDPR: 1. There are clearly two camps on this. I didn’t expect this level of opposition between two visions of what is a personal data breach. 2. One camp adheres to the views […]
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 […]
