On July 7, 2026, the European Data Protection Board (“EDPB”) adopted draft Guidelines 02/2026 on Anonymisation (“Guidelines”), updating a 2014 Opinion on Anonymization Techniques. While the EDPB maintains a cautious approach to anonymization, the new Guidelines appear to offer a more structured and practical framework for assessing whether information can be considered anonymous. The Guidelines are open for public consultation until October 30, 2026.
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Alix Bertrand
Alix advises clients on EU data protection and technology law, with a particular focus on French privacy and data protection requirements. She regularly assists clients in relation to international data transfers, direct marketing rules as well as IT and data protection contracts. Alix is a member of the Paris and Brussels Bars.
CNIL Updates Two Standards For Health Research (MR-001 and MR-003)
On May 26, 2026, the French data protection authority (“CNIL”) published updated versions of its Reference Methodology 001 (“MR-001”, available here in French) and Reference Methodology 003 (“MR-003”, available here in French), two key frameworks governing the processing of personal data in the context of health research.
Continue Reading CNIL Updates Two Standards For Health Research (MR-001 and MR-003)EU AI Act Update: The European Commission Publishes Draft Guidelines on HRAIs
On 19 May 2026, the European Commission published its long-awaited draft, non-binding guidelines on the classification of high-risk AI systems (“HRAIs”) under the EU AI Act (the “Guidelines”). Across three documents—covering general principles, high-risk classification in the context of regulated products (Annex I), and high-risk use cases (Annex III)—the Commission sets out its approach to one of the AI Act’s central questions: when does an AI system fall within the high-risk regime (and, just as importantly, when does it not)?
Rather than restating every aspect of the Guidelines, this post highlights a number of interpretative points likely to matter most in practice.
Continue Reading EU AI Act Update: The European Commission Publishes Draft Guidelines on HRAIsCNIL Publishes Recommendation on Email Tracking Pixels
France’s Highest Administrative Court Upholds CNIL’s Standard On Anonymization
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 AnonymizationEuropean 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 DevelopmentsEU 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 TrialsCJEU 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 OperatorsEDPB 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