The GDPR entered into force on May 25, 2018. One of the GDPR’s core going-forward obligations is the duty to conduct Data Protection Impact Assessments (DPIAs) over processing activities that create a “high risk” to individuals’ privacy. DPIAs constitute an important aspect of GDPR compliance, as they arguably replace the notifications of processing systems and […]
Regulation
On GDPR Day, Austrian DPA issues First Binding DPIA Whitelist
The GDPR entered into force on May 25, 2018. One of the GDPR’s core going-forward obligations is the duty to conduct Data Protection Impact Assessments (DPIAs) over processing activities that create a “high risk” to individuals’ privacy. DPIAs constitute an important aspect of GDPR compliance, as they arguably replace the notifications of processing systems and […]
Belgian Privacy Commission Issues DPIA “Black” and “White List” Recommendation
On February 28, 2018, the Belgian Privacy Commission issued a recommendation on the position it takes with regard to data protection impact assessments (or “DPIAs”) as foreseen in the GDPR. A DPIA under the GDPR is similar in scope and impact to its predecessor, the PIA (or “privacy impact assessment”) and requires businesses to assess […]
In Order, FTC Recognizes Lower Notice Requirements for “Consumer-Expected” Data Collection
Last week, the Federal Trade Commission granted a petition by Sears Holding Management seeking modification of a 2009 Commission Order. The notable 2009 Order settled allegations that Sears had improperly failed to provide notice regarding data collection by certain software the company offered to consumers. Sears argued that the 2009 Order placed it at a […]
German DPAs Publish Model GDPR Processing Records – Translations Provided
In just under 100 days, the EU General Data Protection Regulation (GDPR) enters into force. One of the major changes the GDPR introduces is a duty for in-scope controllers and processors to maintain written records of their processing activities. Under Article 30 GDPR, companies will need to inventory all “processing activities under [their] responsibility” and […]