Nel giugno del 2016, l’Autorità per la protezione dei dati personali (di seguito anche DPA) di Amburgo, in accordo con le altre presenti in Germania, si è occupata della compatibilità di Google Analytics con la normativa nazionale sulla protezione dei dati. Le indicazioni che sono emerse dal provvedimento dell’Autorità di Amburgo appaiono a un primo […]
When a US organization decides to self-certify under the EU-U.S. Privacy Shield, compliance with Privacy Shield principles becomes compulsory. This may be a problem for many US organizations because certain processing activities that they perform – which are perfectly lawful under American law — are unlawful under a Privacy Shield’s perspective. Why? And what to do? Let’s step […]
Francesca Giannoni-Crystal and Cristina Vicarelli In Section 3.5 of Article 29 Working Party (WP29)’s Guidelines on Data Protection Officer (“DPOs”) (“Opinion”), the WP29 discusses the issue of conflict of interest for DPO. See here for more information on this opinion. The WP29 points out that while Article 38(6) GDPR allows a DPO to perform “other tasks and duties”, […]
Article 37(5) General Data Protection Regulation (GDPR) does not list with particularity the professional skills that should be considered when designating the Data Protection Officer (“DPO”). It provides: The data protection officer shall be designated on the basis of professional qualities and, in particular, expert knowledge of data protection law and practices and the ability […]
Article 37(5) General Data Protection Regulation (GDPR) does not list with particularity the professional skills that should be considered when designating the Data Protection Officer (“DPO”). It provides: The data protection officer shall be designated on the basis of professional qualities and, in particular, expert knowledge of data protection law and practices and the ability […]
The Advocate General (AG) of the Court of Justice of the European Union (ECJ) opined on the right to be forgotten in companies’ registers: no right to be forgotten there. In case C-393/15, the Corte di Cassazione (the Italian Supreme Court) asked the ECJ to clarify the right of individuals to be forgotten, to have their […]
On January 12, 2017, Switzerland approved the Swiss-U.S. Privacy Shield Framework. Switzerland considers the agreement as a valid legal mechanism to comply with Swiss requirements when transferring personal data from Switzerland to the United States. The Swiss-U.S. Privacy Shield Framework will replace the U.S.-Swiss Safe Harbor immediately. Switzerland will begin accepting Privacy Shield certifications starting […]
In Section 3.5 of Article 29 Working Party (WP29)’s Guidelines on Data Protection Officer (“DPOs”) (“Opinion”), the WP29 discusses the issue of conflict of interest for DPO. See here for more information on this opinion. The WP29 points out that while Article 38(6) GDPR allows a DPO to perform “other tasks and duties”, the organization must avoid appointment in which those […]
In Section 3.5 of Article 29 Working Party (WP29)’s Guidelines on Data Protection Officer (“DPOs”) (“Opinion”), the WP29 discusses the issue of conflict of interest for DPO. See here for more information on this opinion. The WP29 points out that while Article 38(6) GDPR allows a DPO to perform “other tasks and duties”, the organization […]
According to German data protection law, German data controllers must appoint a Data Protection Officer (“DPO“) in several cases, for example when ten or more people are involved in the automated processing of personal data. While an employee can be appointed as DPO, the appointee must be knowledgeable on data protection and must be reliable and independent. The […]