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Paul Maynard

Paul Maynard is special counsel in the technology regulatory group in the London office. He focuses on advising clients on all aspects of UK and European privacy and cybersecurity law relating to complex and innovative technologies such as adtech, cloud computing and online platforms. He also advises clients on how to respond to law enforcement demands, particularly where such demands are made across borders.

Paul advises emerging and established companies in various sectors, including online retail, software and education technology. His practice covers advice on new legislative proposals, for example on e-privacy and cross-border law enforcement access to data; advice on existing but rapidly-changing rules, such the GDPR and cross-border data transfer rules; and on regulatory investigations in cases of alleged non-compliance, including in relation to online advertising and cybersecurity.

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On 21 January 2026, the European Commission (“Commission”) unveiled its landmark proposal for the Digital Networks Act (“DNA Proposal”), an ambitious attempt to overhaul the framework for the regulation and development of electronic communications networks and services across the EU. The Commission’s stated aim with the DNA Proposal is to establish a “modern and simplified legal framework that incentivises the transition from legacy networks to fibre, high quality 5G and 6G networks, and cloud-based infrastructures, as well as increased scale through service provision and cross-border operation.” To do this, the DNA Proposal would replace and consolidate several existing EU laws, including the European Electronic Communications Code (“EECC”), the BEREC Regulation, and parts of the Open Internet Regulation and e-Privacy Directive.

A key theme of the proposal is harmonization of rules—arising first and foremost from the fact that this is a directly-applicable Regulation rather than a Directive like the current European Electronic Communications Code. Several of the substantive provisions in the DNA Proposal may take a significant amount of influence over the communications networks and services away from Member State governments and up to EU level. In turn, the Commission clearly hopes to promote larger-scale communications network and service providers that can operate across the EU, and that have the funds to invest in modern communications infrastructure. The DNA Proposal could, therefore, have a substantial and long-lasting impact on the connectivity and communications markets in the EU, although we anticipate significant debate about many of the provisions of the DNA Proposal throughout the legislative process.

Below, we summarize seven of the most eye-catching changes to the regulatory framework for communications providers in the DNA Proposal.Continue Reading Seven Major Changes in the European Commission’s Proposal for an EU Digital Networks Act

On 20 January 2026, the European Commission published a proposal for a Regulation to update and replace the Cybersecurity Act (Regulation 2019/881). The proposal—known as the Cybersecurity Act 2 (CSA2)—forms part of a wider package aimed at modernizing and streamlining the EU’s cybersecurity framework and is closely linked to the…

Continue Reading European Commission Proposes Cybersecurity Act 2: New EU Supply Chain Rules and Certification Reforms

On 20 January 2026, the European Commission published a proposal to amend the Directive (EU) 2022/2555 (NIS2) as part of a broader package to streamline the EU’s cybersecurity framework. The Commission also issued a proposal to revise the EU Cybersecurity Act (CSA2), which we cover in a separate blog post.

The proposed amendments build on earlier streamlining efforts in the Commission’s Digital Omnibus Package—published on 19 November 2025—which introduced the first wave of technical adjustments to NIS2. Those earlier amendments focused on creating a single framework for reporting cyber incidents and clarifying how NIS2 interacts with sectoral regimes such as the CER Directive and DORA.

With this proposal, the Commission now aims to clarify the scope of the law, harmonize technical measures, introduce certification‑based compliance pathways, and strengthen cross‑border supervision through an expanded role for ENISA.

Below, we summarize the main elements of the proposal and what they could mean for entities in scope of NIS2.Continue Reading European Commission Proposes Targeted Amendments to NIS2 to Simplify Compliance and Align With Proposed Cybersecurity Act 2

On November 12, 2025, UNESCO’S General Conference adopted its Recommendation on the Ethics of Neurotechnology (“the Recommendation”)–the first attempt at establishing a global legal framework for the ethical development and use of neurotechnology. The Recommendation aims to set out a comprehensive rights-based framework for the entire life cycle of neurotechnology, from the design of neurotechnology products and services to their disposal.

While not legally-binding, the Recommendation states that its provisions should be considered by, among others, UNESCO Member States, research organizations, and private companies involved in neurotechnology, and that they establish how best to honor fundamental human rights in the development, deployment and disposal of this technology. It is therefore possible that in the future, they may be a starting point for binding legislation, or could be used as persuasive authority to support enforcement actions arising under existing legislation protecting fundamental human rights, e.g., the GDPR and other privacy laws around the world. In that regard, it is notable that the EU AI Act was inspired, at least in part, on UNESCO’s November 2021 Recommendation on the Ethics of Artificial Intelligence. There is, therefore, a real possibility that private sector companies developing neurotechnologies will be subject to rules specifically regulating such technologies in the future.Continue Reading UNESCO Adopts First Global Framework on Neurotechnology Ethics

As the UK Government has recognized, cyber incidents—such as Jaguar Land Rover, Marks and Spencer, Royal Mail and the British Library—are costing UK businesses billions annually and causing severe disruption. The Government recognizes that cybersecurity is a critical enabler of economic growth (“we cannot have growth without stability”), and that the current laws have “fallen out of date and are insufficient to tackle the cyber threats faced by the UK.” Accordingly the UK Government this week published its long-awaited Cyber Security and Resilience Bill (the “Bill”), which will amend the existing Network and Information Systems Regulations 2018 (the “NIS Regulations”), and grant new powers to regulators and the Government in relation to cybersecurity.

The NIS Regulations are the UK’s pre-Brexit implementation of Directive (EU) 2016/1148 (the “NIS Directive”), which established a “horizontal” cybersecurity regulatory framework covering essential services in five sectors (transport, energy, drinking water, health, and digital infrastructure) and some digital services (online marketplaces, online search engines, and cloud computing services). EU legislators replaced NIS Directive in 2022 with the “NIS2” Directive, which Member States were meant to transpose into national law by October of last year (although many are still late in doing so. See our post on NIS2 here for an overview of the requirements of NIS2).

The Bill is the UK’s effort at modernizing the framework originally set out in the NIS Directive. In its current form, the Bill will:

  • Significantly expand the scope of the NIS Regulations—to cover, among other things, data centers and managed service providers—and impose additional substantive obligations on covered organizations.
  • Increase potential fines—up to GBP 17m or 4% of the worldwide turnover of an undertaking—and extend the powers of competent authorities to share information with one another, issue guidance, and take enforcement action.
  • Establish a framework for future changes to the NIS Regulations, mechanisms for competent authorities to impose specific cybersecurity requirements on covered organizations, and greater Government direction of cybersecurity matters.

Below, we set out further detail on five major changes in UK cybersecurity regulation arising from the Bill.Continue Reading Five major changes to the regulation of cybersecurity in the UK under the Cyber Security and Resilience Bill

On 24 June 2025, the European Commission published its “roadmap” for ensuring lawful and effective access to data by law enforcement (“Roadmap”). The Roadmap forms a key part of the Commission’s internal security strategy, which was announced in April, and follows on from the November 2024 recommendations of the High-Level Group on Access to Data for Effective Law Enforcement.

Of most immediate relevance to electronic communications service (“ECS”) providers, the Commission intends to propose new data retention requirements, is considering changes to better enable cross-border live interception of communications, and will support the development of tools enabling law enforcement authorities (“LEAs”) to access encrypted data. We describe these proposals, and other elements of the Roadmap, in more detail below.Continue Reading European Commission publishes its plan to enable more effective law enforcement access to data

This blog was prepared in collaboration with, and was originally published by, the UK BioIndustry Association, here. We are grateful to the UK BioIndustry Association for collaborating on this blog, and for the opportunity to post it here.

What are the UK’s plans to reform data protection law?

After an extended period of legislative back and forth, the Data (Use and Access) Bill has now received Royal Assent, becoming the Data (Use and Access) Act (we will therefore refer to it as the “Act” in this blog). The Act addresses various matters related to the use of data, and will to an extent distinguish the UK’s approach to data protection from that set out in the EU’s General Data Protection Regulation (“GDPR”). The European Commission will, therefore, assess whether these changes warrant stripping the UK of its adequacy status for data transfers, with a decision due by 27 December 2025. While the Commission is unlikely to withdraw its finding of adequacy, it is possible that a challenge to this finding could be brought before the Court of Justice of the EU, which could reach a different conclusion.

In summary, the Act is not a complete overhaul of data protection law in the UK; instead, it is more a package of targeted amendments. Of the changes most relevant to biotechs, the most significant is the more permissive regime for the use of personal data for scientific research – although, companies must still meet a number of requirements to fall within scope. More significant changes may take place in the future, as key parts of the Act enable the UK Government to pass secondary legislation in areas that may be relevant to biotechs.Continue Reading The UK’s new Data Legislation – What does it mean for the Life Science sector?

The UK Information Commissioner’s Office (“ICO”) recently announced a new online tracking strategy, which aims to ensure a “fair and transparent online world where people are given meaningful control over how they are tracked online.”

Online advertising is one of the ICO’s current areas of strategic focus (others areas of focus include AI and children’s privacy). The ICO has identified four key areas of concern—all of which the ICO states mean that individuals do not have sufficient control over their personal data:

  • “deceptive or absent choice” regarding non-essential cookies and tracking technologies;
  • “uninformed choice,” which refers to organizations not providing appropriate information to individuals;
  • “undermined choice,” where individuals’ choices are not respected and they are surprised about how their data is used; and
  •  “irrevocable choice,” meaning that individuals cannot effectively change their minds after they have made a choice over how their personal data is processed.

Having identified these areas of concern, the ICO states that it will take the following actions in 2025:Continue Reading ICO announces its online tracking strategy for 2025

In the final quarter of 2024, there have been significant developments in the EU cybersecurity legal landscape. Most prominently, the EU institutions adopted the Cyber Resilience Act and mid-October marked the deadline for Member States to transpose the NIS2 Directive into national law. Most Member States failed to meet the NIS2 transposition deadline, which resulted in the European Commission sending a formal notice to 23 Member States, urging them to transpose the Directive. These 23 Member States have been given two months to respond. (For more information on the Cyber Resilience Act and NIS2 Directive, see our blog posts here and here.)Continue Reading Three Recent Developments in the EU Cyber Landscape

On 2 December 2024, the European Data Protection Board (“EDPB”) adopted its draft guidelines on Article 48 GDPR (the “Draft Guidelines”). The Draft Guidelines are intended to provide guidance on the GDPR requirements applicable to private companies in the EU that receive requests or binding demands for personal data from public authorities (e.g., law enforcement or national security agencies, as well as other regulators) located outside the EU.Continue Reading EDPB adopts draft guidelines on requirements when responding to requests from non-EU public authorities