Late last week, the Article 29 Working Party (“WP29”) issued detailed guidance on companies’ obligations under three key provisions of the General Data Protection Regulation (“GDPR”). This is part two of a three-part Alston & Bird series evaluating WP29’s positions, and relates to the Right of Data Portability for data subjects and its obligations for data controllers. Part 1 deals […]
Privacy & Cyber Regulatory Enforcement
WP29 Releases Extensive Guidance on DPO Obligations; Companies Need to Start Planning Now
Late last week, the Article 29 Working Party (“WP29”) issued detailed guidance on companies’ obligations under three key provisions of the General Data Protection Regulation (GDPR). This is part one of a three-part Alston & Bird series evaluating WP29’s positions, and relates to Data Protection Officer obligations under the GDPR. Part 2 deals with the Right to […]
EU Releases Amendments to Model Clause and Country-Whitelisting Decisions – with Good News for Companies
Most privacy professionals are familiar with the European Court of Justice’s 2015 Schrems decision, which struck down the US-EU Safe Harbor mechanism. One lesser-discussed aspect of the ECJ’s decision related to the powers of Data Protection Authorities (DPAs) within the EU’s Member States. In the Schrems proceedings, the Irish Data Protection Commission argued that it […]
German DPAs to Survey Transfers in 500 Companies – with English Translation of DPA Questionnaire
Late last week, 10 of Germany’s 17 Data Protection Authorities (DPAs) announced they are planning to send written questionnaires to approximately 500 different companies regarding international data transfers. The following provides a brief overview of the situation, as well as an English translation of the questionnaire, for companies who are potentially affected. This summary refers […]
Bank Regulators Issue Advanced Notice of Proposed Rulemaking on Cyber Risk Governance and Management Regulations
More regulators (apart from the FTC) are now taking note of cybersecurity issues in the financial services industry and are taking steps to protect the industry and its consumers. Earlier this year, the Consumer Financial Protection Bureau (“CFPB”) issued its first enforcement action on data security against an online payment system. In June, the Federal […]