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On January 10, 2018, Advocate General Maciej Szpunar (“Advocate General”) of the Court of Justice of the European Union (“CJEU”) issued an Opinion in the case of Google v. CNIL, which is currently pending before the CJEU. In the Opinion, the Advocate General provided his views concerning the territorial scope of the right to be forgotten under the relevant EU Data Protection Directive in the case at hand.

Continue Reading Advocate General Finds Search Engine Operators May Limit the Scope of Right to Be Forgotten to the EU

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: Continue Reading CNIL Publishes Guidance on Data Sharing with Business Partners or Data Brokers

On December 20, 2018, the French data protection authority (the “CNIL”) announced that it levied a €400,000 fine on Uber France SAS, the French establishment of Uber B.V. and Uber Technologies Inc., for failure to implement some basic security measures that made possible the 2016 Uber data breach. Continue Reading CNIL Fines Uber for Data Security Failure Related to 2016 Data Breach

On November 29, 2018, the French Data Protection Authority (the “CNIL”) launched an online public consultation regarding two new CNIL draft standards (“Referentials”) concerning the processing of personal data to manage (1) business activities and (2) unpaid invoices.  Continue Reading CNIL Launches Public Consultation on Draft Standards on Data Processing for Managing Business Activities and Unpaid Invoices

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