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Zooming in on AI – #13: EU AI act– Focus on fundamental rights impact assessment for high-risk AI systems

Companies deploying high-risk artificial intelligence (AI) systems must prepare to conduct Fundamental Rights Impact Assessment (FRIA) by 2 August 2026. In this edition of our “Zooming in on AI” series we explain what this...more

Zooming in on AI #11: EU AI Act – What are the obligations for the limited-risk AI systems

The EU Artificial Intelligence Act (“AI Act”) exemplifies a highly advanced risk-based approach to European regulation. One of its distinguishing features is the detailed classification of various risk levels associated with...more

Germany: Immediate dismissal of board member for email forwarding to personal account

During an investigation, it is not uncommon to discover that an individual has forwarded business emails to their private email address. This ruling from the Higher Regional Court Munich shows the potential implications of...more

Zooming in on AI – #10: EU AI Act – What are the obligations for “high-risk AI systems”?

Companies deploying high-risk artificial intelligence (AI) systems must prepare to navigate a complex landscape of new obligations by August 2, 2026. In this post we explain the key obligations for providers and deployers of...more

European Commission publishes second report on application of GDPR

On 25 July 2024, the EU Commission published its second report on the application of the GDPR (the ‘Second Report’), following its first report published in 2020....more

CJEU issues judgement in two joined cases on right to compensation for non-material damage for identity theft

On June 20, 2024, the Court of Justice of the European Union (‘CJEU’) issued its judgment in two joined cases C-182/22 and C-189/22, Scalable Capital, on the right to compensation for non-material damages under Article 82(1)...more

Automated decision making is under scrutiny in the EU and how is it addressed in other jurisdictions

Alongside the recent CJEU judgment on automated decision making in Schufa (see the Allen & Overy blog ) there are a range of developments related to ADM in other jurisdictions. UK developments - The UK Parliament is...more

CJEU rules that a credit score constitutes automated decision making under the GDPR

On 7 December 2023, the Court of Justice of the European Union (CJEU) issued a landmark judgment on Article 22 of the General Data Protection Regulation (GDPR), focused on decision making based solely on automated processing...more

CJEU considers approach to retention of personal data from public debt registers

In joined Cases C‑26/22 and C‑64/22, related to the German Credit Reference Agency Schufa (see A&O blog on the automated decision making case), the CJEU considered the retention of personal data regarding individuals who had...more

EU-U.S. Data Privacy Framework: adequacy decision adopted, the framework becomes operational

On 10 July 2023, the European Commission adopted the adequacy decision for the EU-U.S. Data Privacy Framework (DPF). This decision enables the free flow of personal data from the EU and three EEA countries (Iceland,...more

Happy birthday, GDPR – five lessons from five years of EU data protection law

In the five years since the European Union’s General Data Protection Regulation came into force, what have been the main learnings for business, and what will the future hold?...more

Increasing global cybersecurity regulation of private companies on the near horizon

Within the past year, a number of countries around the world, including the United States, United Kingdom, France, and The Netherlands have initiated regulatory inquiries and developed new strategies for the purpose of more...more

CJEU rules that national derogations on employees data protection must respect the conditions and limits of Article 88 GDPR

The Court of Justice of the European Union (CJEU) considered appropriate conditions that apply in respect of specific national legislation which EU member states may adopt under Article 88 GDPR to regulate the processing of...more

DSK publishes decision on access by third country public authorities to data processed by processors in the EEA

The German Data Protection Conference of supervisory authorities (DSK) issued a decision on how to evaluate the risk of personal data being accessed by non-EEA public authorities, or by a parent company, when processed by a...more

Germany – Schrems II: German court overturns presumption of international data transfer from EU-subsidiary to non-EU parent...

On 13 July 2022, the Public Procurement Chamber of the German state of Baden-Württemberg (the Public Procurement Chamber) issued a decision confirming that personal data processed by an EU subsidiary of a parent entity...more

CJEU issues opinion in favour of allowing consumer organisations to bring representative actions against GDPR infringement

On 2 December 2021, the Court of Justice of the European Union (CJEU) published the Advocate General’s (AG) opinion in case C-319/20 (Facebook Ireland) (the AG Opinion) relating to the issue of whether Member State law may...more

German Court asks CJEU to clarify whether calculating consumer credit scores falls within the scope of automated decision-making...

On 25 October 2021, the Administrative Court of Wiesbaden (the Court) announced its decision, issued in early October, to submit two questions to the Court of Justice of the European Union (CJEU) regarding the scope of the...more

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