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On March 15, 2021, the state Data Protection Authority of Bavaria declared the use of U.S. e-mail marketing service Mailchimp by a fashion magazine in Bavaria impermissible due to lack of compliance with Schrems II mitigation steps for the transfer of e-mail addresses to the U.S.…
Continue Reading Bavarian DPA Declares Transfers to E-mail Marketing Service Prohibited Due to Lack of Controller’s Assessment and Supplementary Measures

France’s highest administrative court recently issued a summary judgment that rejected a request for the suspension of the partnership between the French Ministry of Health and Doctolib, a leading provider of online medical consultations in Europe, for the management of COVID-19 vaccination appointments. …
Continue Reading French Highest Court Rejects Suspension of Partnership with EU Service Provider Using AWS; Extends Application of the Schrems II Requirements

The concept of regulatory sandboxes has gained traction in the data protection community. Since the UK Information Commissioner’s Office completed its pilot program of regulatory sandboxes in September 2020, two European Data Protection Authorities have created their own sandbox initiatives following the ICO’s framework.…
Continue Reading Regulatory Sandboxes are Gaining Traction with European Data Protection Authorities

On February 5, 2020, the Centre for Information Policy Leadership at Hunton Andrews Kurth submitted a response to the European Commission’s public consultation on the Commission’s Proposal for a Regulation on European Data Governance. This proposal is the first set of initiatives announced under the broader European Data Strategy. …
Continue Reading CIPL Submits Response to European Commission’s Proposal for a Regulation on European Data Governance

On January 27, 2021, the French Data Protection Authority announced that it imposed a fine of 150,000 Euros on a data controller, and a fine of 75,000 Euros on its data processor, for failure to implement adequate security measures to protect customers’ personal data against credential stuffing attacks on the website of the data controller. The CNIL decided not to make its decisions public, thereby not disclosing the name of the companies sanctioned.…
Continue Reading CNIL Fines a Data Controller and Its Processor 225,000 Euros for Security Violation in Connection with Credential Stuffing

On January 26, 2021, BBB National Programs announced that it has been endorsed as an Accountability Agent for the APEC Cross-Border Privacy Rules and Privacy Recognition for Processors systems. This makes BBB National Programs the seventh CBPR and PRP Accountability Agent worldwide and the first ever U.S. non-profit to be approved by APEC.…
Continue Reading APEC Endorses the First U.S. Non-Profit Accountability Agent

The recent UK case of Soriano v Forensic News and Others tested the territorial reach of the General Data Protection Regulation and represents the first UK judgment dealing with the territorial scope of the GDPR. This was a “service out” case, where the claimant, Walter T. Soriano, sought the Court’s permission under the UK Civil Procedure Rules to serve proceedings on the defendants, who were all domiciled in the U.S.…
Continue Reading UK Case Tests the Territorial Application of the GDPR to U.S. Run Website

On January 15, 2020, the European Data Protection Board and European Data Protection Supervisor adopted joint opinions on the draft Standard Contractual Clauses released by the European Commission in November 2020, both for international transfers and for controller-processor relationships within the EEA.…
Continue Reading EDPB and EDPS Adopt Joint Opinions on Draft SCCs

On November 23, 2020, the Centre for Information Policy Leadership at Hunton Andrews Kurth submitted its response to the European Data Protection Board consultation on draft guidelines on relevant and reasoned objections under the General Data Protection Regulation cooperation and consistency mechanisms. This posts provides an overview of the EDPB’s guidelines and highlights CIPL’s response.…
Continue Reading CIPL Submits Response to the EDPB Guidelines 09/2020 on Relevant and Reasoned Objections under the GDPR