Scope: Personal Data

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Anonymisation of personal data: compliance vs utility, regulators vs the law

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 […]

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Making the GDPR realistic? Authorities only want that in part

[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 – […]

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Pseudonymisation & “means reasonably likely to be used” for identification: when does data become personal?

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 […]

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When is data no longer personal? And what are the implications?

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 […]

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Good & bad in judgment on Meta AI training & personal data (legitimate interests, sensitive data) + new French & German guidance

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 […]

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About AI training & legitimate interest as a GDPR legal ground

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 […]

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“Better Regulation”, part II: improving the GDPR – or not? (Art. 1, 2, 4(1), 5 & 30)

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 […]

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“Better Regulation”: Rethinking (or getting rid of?) the ePrivacy Directive

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 […]

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Relative nature of personal data, consent for pseudonymisation? Dissecting the EDPS v SRB AG Opinion

Understanding what is and is not personal data is fundamental to the proper interpretation and enforcement of the most famous data protection law, the GDPR. If no personal data are being processed, the GDPR simply does not apply. Some have considered that “personal data” is an absolute concept, i.e. information can be “in and of […]

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Data Protection Day: podcast on AI & GDPR

Fun 45min interview with Legal4Tech on the GDPR, data protection concerns and AI, the concept of personal data and more – with a short video excerpt here. Listen to the full podcast on Spotify or Apple Podcasts.Happy Data Protection Day! Thanks Rosalia Anna D’Agostino, Giacomo Amodio & Giacomo Di Gregorio for the chat.

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