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Kristof Van Quathem

Kristof Van Quathem advises clients on information technology matters and policy, with a focus on data protection, cybercrime and various EU data-related initiatives, such as the Data Act, the AI Act and EHDS.

Kristof has been specializing in this area for over twenty years and developed particular experience in the life science and information technology sectors. He counsels clients on government affairs strategies concerning EU lawmaking and their compliance with applicable regulatory frameworks, and has represented clients in non-contentious and contentious matters before data protection authorities, national courts and the Court of the Justice of the EU.

Kristof is admitted to practice in Belgium.

On December 4, 2025, the German Federal Government published its Federal Modernization Agenda, setting out a series of suggested amendments to the GDPR and the Federal Data Protection Act (Bundesdatenschutzgesetz). Among the key measures, Germany seeks to shift certain responsibilities from users to manufacturers and providers of standard IT products—following the model of the Cyber Resilience Act (CRA) and the AI Act—so that organizations can deploy standard solutions more easily and in compliance with the law.

The German Data Protection Conference (Datenschutzkonferenz, DSK)—the body of federal and state data protection authorities—has adopted a resolution strongly supporting this approach. The resolution builds on recommendations the DSK first made in its 2019 evaluation of the GDPR.Continue Reading German Government Proposes GDPR Reform to Shift Responsibility to Manufacturers

On December 11, 2025, the CNIL fined an Israeli company €1 million for failing to comply with its GDPR obligations after providing personalized advertising services to an EU music-streaming platform. The service helped the platform to personalize and optimize marketing campaigns to promote its streaming services.

The CNIL held that the GDPR applied to the non-EU processor under Article 3(2), on the basis that it had monitored the behavior of EU users by creating audience segments based on demographics and listening habits, on behalf of the controller.Continue Reading French CNIL Imposes €1M GDPR Fine on Israeli Ad Tech Firm

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

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

On September 17, 2025, the German Supervisory Authorities (Konferenz der unabhängigen Datenschutzaufsichtsbehörden des Bundes und der Länder, DSK) published new guidelines and recommendations addressing the complex requirements for transferring personal data, particularly health data (including health data contained in biomaterials), to countries outside of the European Economic

Continue Reading New German Guidelines on GDPR Requirements for International Transfers of Health Data in Medical Research

On September 16, 2025, the European Commission launched a call for evidence to collect feedback and best practices on simplifying several key areas of the EU digital rulebook, ahead of its planned Digital Omnibus package. This initiative targets legislation related to data, cybersecurity, and artificial intelligence, aiming to reduce administrative burdens and compliance costs for businesses while preserving high standards of fairness, security, and privacy online.Continue Reading Commission Collects Feedback to Simplify Rules on Data, Cybersecurity and Artificial Intelligence in Upcoming Digital Omnibus

On September 4, 2025, the Court of Justice of the EU (“Court”) handed down its judgment in case EDPS v SRB C-413/23 P, setting aside the General Court of the European Union’s (“General Court”) judgment of April 26, 2023 in case SRB v EDPS T‑557/20.  In particular, the Court clarified that whether pseudonymized data can be considered as personal data depends on the specific circumstances of the case, such as whether a third party to whom data is transferred by a data controller can reasonably identify the data subject.

We provide below an overview of the Court’s key findings.Continue Reading EU Court of Justice Clarifies the Concept of Personal Data in the Context of a Transfer of Pseudonymized Data to Third Parties

On July 30, 2025, the Italian Data Protection Authority (“Garante”) released a statement addressing the risks of using AI to interpret medical data.  In this statement, the Garante recognizes the growing trend of individuals uploading medical analyses, X-rays, and other reports onto generative artificial intelligence platforms to obtain interpretations and diagnoses.  It warns users of these AI services to carefully evaluate the implications of sharing health-related data with AI providers and relying on automatically generated responses.Continue Reading Italian Garante Adopts Statement on Health Data and AI

On 15 July 2025, the European Commission adopted an adequacy decision for the European Patent Organisation (EPO).  This marks the first time such a decision has been granted to an international organisation.  From now on, personal data can be transferred from the EU to the EPO based on this decision, without the need for additional safeguards such as Standard Contractual Clauses (SCCs).Continue Reading Adequacy Decision for the European Patent Organisation

On July 17, 2025, the European Commission launched a “call for evidence” and public consultation on the Digital Fairness Act (“DFA”), an anticipated new consumer protection law. The Commission seeks feedback on existing EU consumer protection laws and on proposals for how the DFA could address the following two problems with the existing laws, as identified through a “Fitness Check” of EU consumer law published in October 2024:

  • Lack of digital fairness for consumers. This particularly affects vulnerable groups such as minors, offering them suboptimal choices that can lead to financial harm, loss of time, negative health impacts, and indirect effects like environmental costs.
  • Unclear rules for businesses and market fragmentation. This results in increased business costs, hampers cross-border trade, leads to missed opportunities, and causes unfair competition, particularly from non-EU traders.

The Commission has also emphasized its objective to enhance the EU’s competitiveness, aiming for simplification of consumer protection rules and the removal of barriers within the EU Market. This includes efforts to achieve greater legal certainty regarding unfair commercial practices. The goal is to address enforcement deficiencies, regulatory gaps, and market fragmentation, as some Member States have regulated or are considering new regulation in these areas.Continue Reading Help Shape the New EU Consumer Protection Law: Join the Public Consultation on the Digital Fairness Act