Privacy Shield certification does not mean compliance needs to extend beyond European data

When a US organization decides to self-certify under the EU-U.S. Privacy Shield, compliance with Privacy Shield principles becomes compulsory. This may be a problem for many US organizations because certain processing activities that they perform – which are perfectly lawful under American law — are unlawful under a Privacy Shield’s perspective. Why? And what to do? Let’s step […]

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Privacy Shield certification does not mean compliance needs to extend beyond European data

When a US organization decides to self-certify under the EU-U.S. Privacy Shield, compliance with Privacy Shield principles becomes compulsory. This may be a problem for many US organizations because certain processing activities that they perform – which are perfectly lawful under American law — are unlawful under a Privacy Shield’s perspective. Why? And what to do? Let’s step […]

Who should you appoint as a DPO? The legal/tech/organizational savvy unicorn?

Article 37(5) General Data Protection Regulation (GDPR) does not list with particularity the professional skills that should be considered when designating the Data Protection Officer (“DPO”). It provides: The data protection officer shall be designated on the basis of professional qualities and, in particular, expert knowledge of data protection law and practices and the ability […]

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Who should you appoint as a DPO? The legal/tech/organizational savvy unicorn?

Article 37(5) General Data Protection Regulation (GDPR) does not list with particularity the professional skills that should be considered when designating the Data Protection Officer (“DPO”). It provides: The data protection officer shall be designated on the basis of professional qualities and, in particular, expert knowledge of data protection law and practices and the ability […]

WP29 issues guidelines on data portability, DPO, and lead authority (and lays foundation for much more)

  On December 13, 2016, EU Article 29 Data Protection Working Party “(WP29”) dealt with several critical matters with regards to the implementation of the General Data Protection Regulation (GDPR) and the Privacy Shield. It also dealt with the enforcement measures on cases having a cross-border effect. As for the GDPR’s implementation, the WP29 importantly adopted: […]

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European cloud providers’ association issues data protection code of conduct

On September 27, 2016, the Cloud Infrastructure Services Providers of Europe (CISPE) announced the publication of the Data Protection Code of Conduct for Cloud Infrastructures Services. The CISPE comprises several major European cloud infrastructure providers. The code of conduct provides that the certified cloud infrastructure providers: will process and store data exclusively within the EU/EEA […]

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Privacy notices, transparency and control – ICO’s good practices

On October 25, 2016, the UK Information Commissioner’s Office (ICO) issued a revised code of practice and checklist on privacy notices, transparency and control. The code helps organizations required by the Data Protection Act 1998 (DPA) to “collect information about people, whether directly or indirectly” to provide transparent and accessible “privacy notices” to data subjects. The […]

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The privacy problem of cookie-free tracking methods: device fingerprinting

Cookie regulation in Europe is quite strict. In a previous blog we discussed the cookie law of France, Germany, Italy and the UK, focusing on information to users, user consent and consequences of violations. However, cookies are not the only method to track users. There are cookie-free tracking methods that are similarly invasive, for example […]

EU Data Protection – glossary

Thanking CORDERY, we gladly publish the EU Data Protection – glossary (originally published by Cordery at http://www.corderycompliance.com/eu-data-protection-regulation-glossary/) We’ve put together this glossary to help explain some of the terms used in data protection and in the GDPR. If there’s a term you think we should add let us know. Agencia de Proteccción de Datos = the Spanish […]

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