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On August 7, 2019, the Centre for Information Policy Leadership at Hunton Andrews Kurth LLP issued a white paper on “Key Issues Relating to Standard Contractual Clauses for International Transfers and the Way Forward for New Standard Contractual Clauses under the GDPR.” The White Paper was submitted to the European Commission as part of its ongoing work to update EU Standard Contractual Clauses for international transfers.…
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On July 29, 2019, the Court of Justice of the European Union released its judgment in case C-40/17, Fashion ID GmbH & Co. KG vs. Verbraucherzentrale NRW eV, ruling that Fashion ID should be considered a joint controller with Facebook regarding the collection and disclosure of personal data to Facebook as a result of embedding the Facebook ‘Like’ button on its website.…
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On July 25, 2019, the French Data Protection Authority (the “CNIL”) published new template records of data processing activities pursuant to Article 30 of the EU General Data Protection Regulation (“GDPR”). This provision requires organizations subject to the GDPR to maintain internal records of data processing activities. The CNIL recalled that such records are a key accountability tool under the GDPR for identifying, understanding and controlling data processing activities. Setting up and maintaining these records provide businesses with the opportunity to ask the right questions and limit privacy risks under the GDPR. According to the CNIL, this is also a useful moment to set up a data protection compliance action plan.
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