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Belgian DPA Finds Broad Tax Information Transfers to IRS Unlawful

The Belgian Data Protection Authority recently ruled that a Belgian government entity, FPS Finance, cannot transfer the personal data of “accidental Americans” to the IRS. According to the decision, the transfers needed to...more

Forget It!: EDPB Announces Focus on Right to Erasure in 2025

Right of erasure (or “right to be forgotten”) has been selected by the European Data Protection Board as its priority enforcement topic for 2025. This work is being done under the “Coordinated Enforcement Framework” or “CEF.”...more

EU Fines EU?!: Alleged Unlawful Data-Transfer Dust-Up

Following a German case brought against the EU Commission, the EU General Court found that the Commission had made an improper transfer of personal information to the US. The plaintiff, a German citizen, alleged (among other...more

Don’t Forget the EU: Italy Issued First GenAI Fine of €15 Million Alleging GDPR Violations 

At the end of 2024 the Italian Data Protection Authority issued a 15 million euro fine in the first generative AI-related case brought under GDPR. According to Garante (the Italian authority), OpenAI trained ChatGPT with...more

Sheppard Mullin’s 2024 Eye on Privacy Year in Review

It is hard to believe that another year is upon us! As we have done in years past (including 2023, 2022, 2021, 2020, 2019 and 2018), we have created a comprehensive resource of all our www.eyeonprivacy.com posts from 2024. As...more

How Legitimate Is Your Business Interest? The EDPB Has Some Thoughts

The European Data Protection Board issued draft guidelines last month that outline when processing can be considered done for “legitimate interest.” The public has until November 20 to provide comments to the draft....more

EDPB Provides Insight for Use of Tracking Tools

The EDPB released guidance last month to help companies understand their obligations when using newer tracking tools. These include pixels, URL tracking, IP-tracking, and the like. First, some background: an EU law that...more

Brazil’s Data Protection Authority Issues Rules Clarifying Data Transfers

Wondering what the requirements are for transferring personal information out of Brazil? Under the country’s Data Protection Law, extra-territorial transfers of personal information are regulated in much the same way as in EU...more

AI Summer Roundup: EU and Colorado Celebrate Summer with AI Legislation

As we enter the end of the summer, the AI regulatory steam is not slowing down. Colorado is now the first US state to have a comprehensive AI law (going into effect February 1, 2026), and the EU published its sweeping AI law...more

EDPB Provides Guidance on Determining Primary Supervisory Authority

This month the EDPB shed light on the question of lead supervisory authorities. The issue arose in response to a question late last month from the French supervisory authority. Some background. As most international...more

DPA 101: Do You Know Where Your Data Is?

As more and more states enact laws that mirror aspects of GDPR, and as companies begin to get used to the EU’s new standard contractual clauses, now may be a good opportunity for a refresh on data sharing agreements. As most...more

Connected Devices: Eyes on EU Data Act

The European Council recently approved a final version of the EU Data Act. The Act applies to manufacturers of connected devices. Among other things, it gives consumers certain rights about the information those devices...more

CNIL Fines Canal+ Over Marketing and Data Security Concerns

The French Data Protection Authority announced a €600,000 fine against Groupe Canal+ over concerns with the media company’s direct marketing activities. According to the CNIL, the company sent users email marketing without...more

No Need to Mind the Gap – UK Extension is a Data Bridge for US-UK Data Transfers

Beginning today, the UK adequacy decision for US data protection measures goes into effect. As a result, UK companies can transfer personal information to entities in the US that are participants in the EU-US Data Privacy...more

Considerations for Participation in the EU-US Data Privacy Framework

Now that the EU has adopted its adequacy decision for the EU-US Data Privacy Framework (DPF), many companies are assessing whether participation makes sense. Participation by a US entity is a mechanism -but not the only...more

EU Adopts Adequacy Decision for EU-US Data Privacy Framework

The EU Commission adopted today an adequacy decision for the EU-US Data Privacy Framework. As we indicated last month, this has been an area closely watched by those transferring data from the EU to the US. The issue has been...more

EDPB Adopts Binding Corporate Rules Recommendations

As those in the privacy world await the outcome of the EU-US privacy framework negotiations, the EDPB was in the news recently for a different mechanism for data transfers: Binding Corporate Rules. Namely, it adopted...more

Where Do We Stand?: EU to US Data Transfers

The process for data transfers from the EU to the US under Standard Contractual Clauses has been back in the news recently, leading many to ask: will the proposed EU-US Data Privacy Framework be approved by the Europeans...more

CNIL Weighs in On GDPR Applicability to US Company

The French Data Protection Authority capped off 2022 by terminating an investigation into Lusha Systems, Inc.’s compliance with GDPR. CNIL concluded that the law did not apply to the US company’s activities...more

EU’s Initial Response to US Proposed Data Transfers Framework

The EU released its draft adequacy decision for the EU-US Data Privacy Framework, but all is not smooth sailing. As we wrote in October, the US developed the proposed new framework in response to the declared inadequacy of...more

EU To Review New EU-US Data Transfers Framework

President Biden signed a new executive order on Friday, with a framework that seeks to replace the existing Privacy Shield program. That program was found to be an invalid mechanism for transferring personal data between the...more

Deadlines for EU and UK Standard Contractual Clauses Approaching

Companies transferring personal data out of the EU or UK are reminded of key deadlines approaching for the contracts that govern these transfers. When the European Commission adopted the new Standard Contractual Clauses...more

What’s the Big Deal About Dark Patterns?

Dark patterns have been a recent regulatory focus. The FTC issued an enforcement policy late last year, and the European Data Protection Board followed suit with guidelines this spring. The two have slightly different takes...more

Interactive Advertising Bureau of Europe Fined By Belgian DPA for GDPR Violation

The Belgian Data Protection Authority (APD) recently released a draft decision imposing a €250,000 fine ($285,000) on the provider of a consent mechanism that operates within a real-time ad bidding program. The ad bidding...more

CNIL Recommends Using US Analytics Tools Only for Anonymous Statistical Data

Following a similar case from Austria, the French data protection authority recently concluded that certain use of cookies placed by US data analytics tools violated GDPR. The case came before the CNIL as the result of a...more

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