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On November 6, 2018, the French Data Protection Authority (the “CNIL”) published its own guidelines on data protection impact assessments (the “Guidelines”) and a list of processing operations that require a data protection impact assessment (“DPIA”). Read the guidelines and list of processing operations (in French). Continue Reading CNIL Publishes DPIA Guidelines and List of Processing Operations Subject To DPIA

On October 17, 2018, the French data protection authority (the “CNIL”) published a press release detailing the rules applicable to devices that compile aggregated and anonymous statistics from personal data—for example, mobile phone identifiers (i.e., media access control or “MAC” address) —for purposes such as measuring advertising audience in a given space and analyzing flow in shopping malls and other public areas. Read the press release (in French). Continue Reading CNIL Details Rules On Audience and Traffic Measuring In Publicly Accessible Areas

Recently, the French Data Protection Authority (the “CNIL”) published a statistical review of personal data breaches during the first four months of the EU General Data Protection Regulation’s (“GDPR”) entry into application. View the review (in French).  Continue Reading CNIL Publishes Statistical Review of Data Breaches Since Entry into Application of GDPR

On October 11, 2018, the French data protection authority (the “CNIL”) announced that it adopted two referentials (i.e., guidelines) on the certification of the data protection officer (“DPO”). View the announcement (in French). As a practical matter, both referentials are intended to apply to DPOs located in France or who speak French. The referentials include: Continue Reading CNIL Adopts Referentials on DPO Certification

Recently, the French Data Protection Authority (“CNIL”) published its initial assessment of the compatibility of blockchain technology with the EU General Data Protection Regulation (GDPR) and proposed concrete solutions for organizations wishing to use blockchain technology when implementing data processing activities. Continue Reading CNIL Publishes Initial Assessment on Blockchain and GDPR

On September 25, 2018, the French Data Protection Authority (the “CNIL”) published the first results of its factual assessment of the implementation of the EU General Data Protection Regulation (GDPR) in France and in Europe. When making this assessment, the CNIL first recalled the current status of the French legal framework, and provided key figures on the implementation of the GDPR from the perspective of privacy experts, private individuals and EU supervisory authorities. The CNIL then announced that it will adopt new GDPR tools in the near future. Read the full factual assessment (in French). Continue Reading CNIL Publishes Initial Assessment of GDPR Implementation

On July 19, 2018, the French Data Protection Authority (“CNIL”) announced that it served a formal notice to two advertising startups headquartered in France, FIDZUP and TEEMO. Both companies collect personal data from mobile phones via software development kit (“SDK”) tools integrated into the code of their partners’ mobile apps—even when the apps are not in use—and process the data to conduct marketing campaigns on mobile phones. Continue Reading CNIL Serves Formal Notice to Marketing Companies to Obtain User’s Consent for Processing Geolocation Data for Ad Targeting

On December 18, 2017, the French data protection authority (“CNIL”) publicly announced that it served a formal notice to WhatsApp regarding the sharing of WhatsApp users’ data with Facebook Inc. (“Facebook”). This decision, dated November 27, 2017, follows the CNIL’s investigations regarding Facebook’s 2014 acquisition of WhatsApp. In 2016, WhatsApp updated its Terms of Service and Privacy Policy to reflect the sharing of information with Facebook. Following this update, the Article 29 Working Party (“Working Party”) requested explanations from WhatsApp on its data processing practices and data sharing, and asked the company to stop sharing data for targeted advertising purposes. The Working Party also gave a mandate to its subgroup in charge of the cooperation on investigations and sanctions to coordinate actions of the relevant national data protection authorities. It is in that context that the CNIL started its investigation of WhatsApp’s data processing practices. Continue Reading The CNIL Serves Formal Notice to WhatsApp Regarding Sharing Data with Facebook

On October 17, 2017, the French Data Protection Authority (“CNIL”), after a consultation with multiple industry participants that was launched on March 23, 2016, published its compliance pack on connected vehicles (the “Pack”) in line with its report of October 3, 2016. The Pack applies to connected vehicles for private use only (not to Intelligent Transport Systems), and describes the main principles data controllers must adhere to under both the current French legislation and the EU General Data Protection Regulation (“GDPR”).    Continue Reading French DPA Publishes a Compliance Pack Regarding Connected Vehicles

The Centre for Information Policy Leadership at Hunton & Williams LLP (“CIPL”) recently submitted responses to the Irish Data Protection Commissioner (IDPC Response) and the CNIL (CNIL Response) on their public consultations, seeking views on transparency and international data transfers under the EU General Data Protection Regulation (“GDPR”).

The responses address a variety of questions posed by both data protection authorities (“DPAs”) and aim to provide insight on and highlight issues surrounding transparency and international transfers. Continue Reading CIPL Responds to CNIL and Irish DPC on Transparency and Data Transfers under the GDPR