On January 10, 2018, Advocate General Szpunar of the Court of Justice of the European Union issued an Opinion in the case of Google v. CNIL, which is currently pending before the CJEU. In its Opinion, the Advocate General provided his views concerning the territorial scope of the right to be forgotten under the EU Data Protection Directive.
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On December 28, 2018, the French Data Protection Authority (the “CNIL”) published guidance regarding the conditions to be met by organizations in order to lawfully share personal data with business partners or other third parties, such as data brokers. The guidance focused, in particular, on such a scenario in the context of the EU General Data Protection Regulation (“GDPR”). The CNIL guidance sets forth the 5 following conditions:
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