German DPAs

German DPAs Issue DPIA Blacklists; Many Companies Likely to be Affected

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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 activities to European Data Protection Authorities (DPAs) which pre-GDPR privacy law often obligated companies to make.  Instead of notifying DPAs, the GDPR now requires companies to internally conduct DPIAs that document “high [...] Read more

German DPAs Publish Model GDPR Processing Records – Translations Provided

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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 memorialize them in a written record setting forth, inter alia, the purposes of processing operations, international transfers, and retention periods. Article 30 GDPR thus creates a new kind of documentation obligation.  This obligation [...] Read more