personal data

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Individuals are increasingly making use of their right to access their personal data under applicable privacy laws in the EU.

It can be a challenge for companies to handle such requests, and in particular, if a request concerns a complex data set, there are a high number of requests, or the right is exercised for strategic reasons, such as in HR or legal disputes. The right of access is, however, not absolute, and its restrictions vary across Member States, adding further complexity to the matter. How to handle such requests and apply these restrictions is commonly set out in internal policies and procedures. We set out below the current landscape as well as a recent enforcement trend.Continue Reading Weaponization of Data Subject Access Requests in the EU

On June 20, 2019, the UK’s Data Protection Authority (ICO) published a report on adtech and real-time bidding. The report highlights the main problems faced by the industry when applying the General Data Protection Regulation’s (GDPR’s) stringent requirements, and calls for further engagement on these issues by the different adtech players in the space.

Background

When the GDPR became effective on May 25, 2018, it imposed new and strict obligations on companies processing personal data. In the UK, the Privacy and Electronic Communications Regulations (PECR), which implements the EU e-Privacy Directive and will soon be replaced by the e-Privacy Regulation, complements the GDPR requirements. Both the GDPR and PECR govern how data is collected and further processed in the online advertising industry, including requiring notice and a legal basis for processing. The PECR specifically applies to the use of cookies and similar technologies and sets out the rules for consent to use these technologies.Continue Reading The ICO Publishes Its Stance on Adtech and Real-Time Bidding