The European Data Protection Board (“EDPB”) has published draft guidelines on the concepts of controller and processor for public consultation. While its predecessor – the Article 29 Working Party – had issued guidance on the concepts of controller/processor (Opinion 1/2010, WP169) back in 2010, many practical concerns have been raised since the entry into force […]
Privacy & Cyber Regulatory Enforcement
European Parliament Committee Meeting Provides Insight into the Future of EU-US Personal Data Flows
On September 3, 2020, The EU Parliament’s Committee on Civil Liberties, Justice and Home Affairs (the LIBE Committee), met to discuss the future of future of EU-US personal data flows following the Schrems II decision. In particular, the session was attended by Max Schrems, EU Commissioner for Justice Didier Reynders, and Andrea Jelinek (head of […]
California Passes Bill Extending Exemptions for Employment and Business-to-Business Information Under the CCPA
On Friday, August 28, the California state legislature passed Assembly Bill 1281 (“AB 1281”), potentially extending until January 1, 2022 the partial exemptions for employment and business-to-business data under the California Consumer Privacy Act (the “CCPA”). AB 1281 only takes effect if the California Privacy Rights Act of 2020 (the “CPRA”), an initiative to amend […]
German DPA Publishes Schrems II Transfer Compliance Checklist and Suggested Modifications to SCCs
On August 24, 2020, the data protection authority of the German state of Baden-Württemberg (the “DPA”) published guidance (the “Guidance”) on international transfers of personal data following the Schrems II judgment (which we have previously covered here). This represents the first comprehensive guidance by a European privacy supervisor indicating how it intends to enforce the […]
Final CCPA Regulations Approved, Effective Immediately
On Friday, August 14, 2020, the California Office of Administrative Law (OAL) approved the California Office of the Attorney General’s (OAG) Final CCPA Regulations (the “Regulations”) and filed them with California Secretary of State. The Regulations became effective immediately. The OAL-approved Regulations contain several modifications from prior versions. While many of the changes are purely […]