Tag Archives: privacy

EDPB Issues Guidelines on Social Media Targeting Under GDPR

On Monday September 7, 2020, the European Data Protection Board (EDPB) issued draft Guidelines 8/2020 on the targeting of social media users (the “Draft Guidelines”). The Draft Guidelines have far-reaching implications for social media platforms, advertisers, and adtech companies, as they will result in a clarification of the roles and responsibilities of the key stakeholders, and establish … Continue Reading

EDPB Adopts Updated Consent Guidance

On May 4, 2020, the European Data Protection Board (EDPB) adopted new guidelines (the guidelines) regarding the use of consent as a legal basis for processing personal data under the General Data Protection Regulation (GDPR).[1] The guidelines update and replace the Article 29 Working Party’s April 2018 guidance on the same topic. The guidelines remain … Continue Reading

EDPB Publishes Guidelines on COVID-19 Related Data Usage

On April 21, 2020, the European Data Protection Board (EDPB) published two sets of guidelines addressing data processing in the context of the COVID-19 pandemic. These guidelines address the use of location data and contact tracing tools to combat the spread of COVID-19 and the use of health data for the purposes of scientific research into COVID-19 (together, the … Continue Reading

The European Commission Publishes Guidance on COVID-19 Mobile Apps

On April 16, 2020, the European Commission (EC) published guidance (guidance) regarding mobile applications developed to combat the spread of the COVID-19 pandemic (COVID-19 mobile apps). As previously mentioned in our blog posts, the guidance follows the EC recommendation last week on the same topic, and takes into account a prior consultation with the European … Continue Reading

The EDPB Responds to the European Commission’s Recommendation on COVID-19 Mobile Apps

On April 14, 2020, the European Data Protection Board (the EDPB) published a letter in response to the European Commission’s call for consultation (the letter) regarding its recommendation on the use of mobile applications and location data to fight the COVID-19 outbreak. As previously reported in our blog post, the European Commission’s recommendation sets out a “toolbox” of measures … Continue Reading

European Commission Calls for a Common Approach to COVID-19 Apps and Anonymized Data Use

On April 8, 2020, the European Commission (the Commission) released its recommendation for a pan-EU approach on the use of technology and data to combat the COVID-19 pandemic (the Recommendation). The Commission calls for the creation of a “toolbox” consisting of practical measures taken at the EU level to address the use of mobile applications … Continue Reading

Non-EEA Based Vendors Caught by GDPR’s Long-Arm Provisions

The General Data Protection Regulation (GDPR) does not just impact companies located in the European Economic Area (EEA). It has a “long-arm” provision which may subject foreign companies to its jurisdiction. There is a fair amount of uncertainty regarding how this provision may be applied. The European Data Protection Board (EDPB) has recently issued updated … Continue Reading

Third Time’s the Charm? Newest Round of Modifications to Proposed CCPA Regulations Issued by the California Attorney General

On March 11, 2020, the California Attorney General issued further revisions to the proposed regulations implementing the California Consumer Privacy Act (CCPA). For context, in passing the CCPA, the legislature directed the California Attorney General to solicit broad public participation and adopt regulations to further the purposes of the CCPA. On October 11, 2019, the California Attorney … Continue Reading

EU Privacy Regulators Issue Draft Guidelines on Connected Vehicles and Mobility Applications

On February 7, 2020, the European Data Protection Board (EDPB) published draft guidelines on the processing of personal data in the context of connected vehicles and mobility related applications. If adopted in their current form, the draft guidelines will have far-reaching consequences for connected vehicles and mobility applications that operate in Europe. They contain detailed interpretations of … Continue Reading

CCPA Update: California Attorney General Issues Modifications to Proposed CCPA Regulations

Updates to Compliance Likely Required On February 10, 2020, the California Attorney General issued the proposed text of modified regulations implementing the California Consumer Privacy Act (CCPA). This draft is a correction of a version that the California Attorney General issued on February 7, 2020. While the California Attorney General previously indicated that major changes to the … Continue Reading

CJEU Advocate General Confirms Validity of EU Data Transfer Tools

On December 19, 2019, the Advocate General (AG) of the highest EU Court (the Court of Justice of the European Union (CJEU)) issued his opinion in Schrems II[1] (the opinion). Wilson Sonsini previously covered the key points of the opinion in our Alert of December 20 and now provides a more detailed analysis in this … Continue Reading

Update: UK’s Age Appropriate Design Code

On January 21, 2020, the Information Commissioner’s Office (ICO) published its final version of its Age Appropriate Design Code of Practice (the code). The code will be submitted to Parliament in the coming days, and, assuming there is no objection, will become effective approximately two months later. This blog post follows our previous update on … Continue Reading

European Privacy Landscape: What to Expect in 2020

The year 2020 promises to be an interesting one for privacy and data protection in Europe. In this post, we highlight four of the most important developments to watch this year: 1) we expect that European Union (EU) regulators will ramp up GDPR enforcement across the board, and with a particular focus on AdTech, cookies, … Continue Reading

Data Brokers Must Register with California Attorney General by January 31

Given Broad Definitions, the Law Could Apply to Businesses That Do Not Consider Themselves Data Brokers While amending the California Consumer Privacy Act of 2018 (CCPA) last term, the California legislature also passed a CCPA-related privacy bill that applies to “data brokers.” Assembly Bill 1202 (AB 1202) requires businesses that qualify as data brokers to register, pay … Continue Reading

Proposed CCPA Regulations: Clarity or Confusion?

On October 10, 2019, the California Attorney General’s office issued the proposed text of its California Consumer Privacy Act (CCPA) regulations (the Regulations). The Regulations propose detailed rules regarding required notices for consumers, business practices for handling consumer requests, verification of requests, special rules regarding minors, and non-discrimination. Accompanying the Regulations are the Attorney General’s … Continue Reading

Greece Publishes Draft Legislation for Implementing GDPR

On August 12, 2019, the Greek Ministry of Justice published the long-awaited, draft legislation for implementing the General Data Protection Regulation (GDPR). Greece and Slovenia are the only two European Union (EU) countries that have not yet implemented the GDPR. As an EU regulation, the GDPR has legally taken effect in every EU country, including … Continue Reading

Website Operator Jointly Liable for Data Collection and Transmission Through Facebook “Like” Button

On July 29, 2019, the European Court of Justice (ECJ) issued its decision in FashionID (Case C-40/17), determining that website operators are jointly liable with plugin providers for data collection and transmission through social media buttons and other embedded plugins. Although the ECJ found the operator and plugin provider to be jointly liable, the court placed the … Continue Reading

The ICO Issues Its Cookies Guidance: Clarified Stance and Enforcement Priorities

On July 5, 2019, the UK’s Data Protection Authority (ICO) issued its “Guidance on the use of cookies and similar technologies” (the Guidance) along with a brief explanatory blog post. At the same time the ICO updated its own website cookie notice and consent, leading by example. The ICO’s blog post makes clear that cookie … Continue Reading

The CNIL Announces Its 2019-2020 Action Plan on Ad Targeting

On June 28, 2019, the French Data Protection Authority (CNIL) released its 2019-2020 action plan on ad targeting (action plan);1 among other things, the CNIL announced that it will issue new cookie guidance later this month and that, once the guidance is published, companies will have a 12-month grace period to come into compliance. Background … Continue Reading

Massive GDPR Fine Proposed by UK ICO Confirms Trend of Increased Focus on EU Data Breaches

On July 8, 2019, the UK Information Commissioner’s Office (ICO) announced its intention to fine British Airways GBP 183.39 million over a data breach in which the personal data of approximately 500,000 customers was compromised.[1] If made final, the fine—equivalent to approximately U.S. $230 million—would be the biggest fine ever issued by the ICO as … Continue Reading
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