On February 13, 2026, France’s highest administrative court (“Conseil d’État”) delivered an important decision clarifying the boundary between pseudonymization and anonymization under the GDPR. The ruling confirms that data which remain re‑identifiable in practice—even with some effort—must be treated as personal data under the GDPR by service providers, unless the risk of re‑identification by such providers can genuinely be regarded as insignificant.Continue Reading France’s Highest Administrative Court Upholds CNIL’s Standard On Anonymization
European Data Protection Authorities Issue Joint Opinion on the Digital Omnibus on AI
What to Watch in 2026: Key EU Privacy & Cybersecurity Developments
As 2026 gets underway, the European Union enters a pivotal year for data protection, AI governance, and cybersecurity regulation, among other matters. EU institutions and national authorities are expected to progress a number of significant digital‑policy files, roll‑out new cyber‑resilience obligations, and make transparency in the privacy space a top priority. Below is an overview of the key developments to monitor.Continue Reading What to Watch in 2026: Key EU Privacy & Cybersecurity Developments
EU Biotech Act Suggests Clarifying Data Protection Rules For Clinical Trials
On December 16, 2025, the EU Commission unveiled its proposal for the Biotech Act. The proposal, which is only the first part of a bigger initiative for regulating biotechnologies, focuses primarily on the health sector. The Commission took the opportunity to broadly revise the Clinical Trial Regulation (“CTR”) – see our blog post here. In particular, it sought to better align the CTR requirements with those of the General Data Protection Regulation (“GDPR”). This blog post provides an overview of those revisions relating to the processing of personal data during clinical trials.Continue Reading EU Biotech Act Suggests Clarifying Data Protection Rules For Clinical Trials
CJEU Clarifies Responsibilities Of Online Marketplace Operators
On December 2, 2025, the Court of Justice of the European Union (“CJEU”) issued a decision clarifying the obligations of online marketplace operators with regard to content posted on their platform, where such content includes personal data. This blogpost provides an overview of the decision and its key takeaways.Continue Reading CJEU Clarifies Responsibilities Of Online Marketplace Operators
EDPB to Focus on Transparency in 2026 Enforcement
On October 14, 2025, the European Data Protection Board (“EDPB”) announced that its 2026 coordinated enforcement action (“CEA”) will focus on transparency and information obligations — the rules that require organizations to clearly explain how they collect, use, and share personal data — under Articles 12-14 of the General Data Protection Regulation (“GDPR”).Continue Reading EDPB to Focus on Transparency in 2026 Enforcement
French CNIL Issues Draft Guidance On The Use of Location Data From Connected Vehicles
On March 25, 2025, the French data protection authority (“CNIL”) published a draft recommendation on the use of location data from connected vehicles (the “Recommendation” – see here in French). The Recommendation is open for public consultation until May 20, 2025.Continue Reading French CNIL Issues Draft Guidance On The Use of Location Data From Connected Vehicles
Digital Fairness Act Series – Topic 1: Influencer Marketing
The European Commission (“Commission”) is working on a new EU consumer protection law called the Digital Fairness Act (“DFA”) to better protect consumers in the digital space. The DFA is expected to regulate, among other things, influencer marketing.
With EU consumer protection watchdogs starting to bring cases against companies whose products or services are promoted by influencers (see for example here), the DFA’s provisions may apply not only to influencers, but also to companies that deploy or use influencers, to ensure that advertising practices are fair and transparent. This blog post explores two key issues that the European Commission is expected to prioritize in its approach to influencer marketing. It also provides a brief overview of the French legal framework in this area, which some expect to serve as a model for the EU’s forthcoming rules in this area.Continue Reading Digital Fairness Act Series – Topic 1: Influencer Marketing
CJEU Finds Customers’ Title Is Not Necessary Data For The Purchase Of A Train Ticket
On January 9, 2025, the Court of Justice of the European Union (“CJEU”) issued a decision on the GDPR’s lawfulness and data minimization principles.
The case arose after a French association (“Mousse”) complained to the French Supervisory Authority (“CNIL”) about the fact that France’s main train company SNCF requires customers to indicate their title and gender identity by ticking either “Sir” or “Madam” when purchasing a train ticket online. Mousse considered that such a mandatory requirement could not be justified under the “contractual performance” or “legitimate interests” legal bases set out in Article 6 GDPR, and infringed the GDPR’s principles of lawfulness, data minimization and transparency.
The CNIL dismissed the complaint, and Mousse appealed the CNIL’s decision before the French Administrative Supreme Court (“Conseil d’Etat”), which stayed the proceedings to refer some questions to the CJEU.Continue Reading CJEU Finds Customers’ Title Is Not Necessary Data For The Purchase Of A Train Ticket
CNIL Opens Public Consultation on Its Standards for Processing Health Data
On May 16, 2024, the CNIL launched a public consultation on all of its health data standards. Interested stakeholders are encouraged to participate by completing a questionnaire (available in French here) by July 12, 2024.
French law has specific requirements for the processing of health data. In particular, it
Continue Reading CNIL Opens Public Consultation on Its Standards for Processing Health Data