GDPR

On July 20, 2026, the French data protection authority (the Commission Nationale de l’Informatique et des Libertés, “CNIL”) published a joint exploratory note with the French AI and Digital Council (“CIANum”) on the data protection implications of agentic AI (the “Note”). The Note is exploratory rather than prescriptive: it does not purport to state definitive regulatory expectations, and it does not announce forthcoming guidance. However, it does provide helpful considerations for when the EU’s General Data Protection Regulation (“GDPR”) might come under strain in the course of processing personal data via autonomous systems, and identifies legal and technical measures that might help mitigate potential risks. The CNIL frames this exercise as connected to its engagement with several international counterparts, including through the G7 data protection authorities during the French G7 presidency.

The Note is the latest in a rapidly accumulating body of regulator commentary on agentic AI, including by the UK ICO, Spanish AEPD, and Singaporean IMDA. Below are some key takeaways.

Continue Reading French CNIL Publishes Note on Agentic AI and Data Protection

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.

Continue Reading EDPB Publishes Draft Guidelines on Anonymisation

On April 17, 2026, the Italian data protection authority (the “Garante”) published Provision No. 284 setting out guidelines on the use of “tracking pixels” in emails (the “Guidelines”). This publication closely follows the recommendation issued by the French data protection authority on the same topic, which is discussed in a…

Continue Reading Italian DPA Publishes Guidelines on Email Tracking Pixels

On March 25, 2026, the UK’s Office of Communications (“Ofcom”) and the Information Commissioner’s Office (“ICO”) published a joint statement setting out their common expectations for age assurance on online services (“Joint Statement”). The Joint Statement is aimed at services likely to be accessed by children that fall within the scope of the Online Safety Act 2023 (“OSA”) and UK data protection legislation, and is designed to help providers comply with both their online safety and data protection obligations when deploying age assurance.

The Joint Statement arrives alongside a broader push from both regulators—including Ofcom’s recent call to action directed at major tech firms, an open letter from the ICO urging platforms to strengthen their age checks, and several enforcement actions by both regulators.

Continue Reading Ofcom and ICO Issue Joint Statement on Age Assurance

On March 19, 2026, the CJEU issued its judgment in the Brillen Rottler case (C‑526/24).  The case concerns the GDPR right of access and the conditions for claiming damages.  In the underlying facts, an Austrian individual subscribed to Brillen Rottler’s newsletter and, two weeks later, exercised his right of access.

Continue Reading EU Court Defines Limits to the GDPR Right of Access

On March 12, 2026, the Italian Data Protection (“Garante”) adopted a decision concerning the transfer of personal data of banking customers from Intesa Sanpaolo S.p.A. (the “Bank”) to Isybank S.p.A., a newly established digital bank within the same corporate group.  The Garante found that the Bank’s processing in connection with the transfer of approximately 2.4 million customers to Isybank was unlawful.

We set out the decision’s key findings below.

Continue Reading Italian DPA Fines Bank over the Transfer of Customer Data in the Context of a Corporate Transaction

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

On February 19, 2026, the UK Court of Appeal handed down its decision in DSG Retail Limited v The Information Commissioner [2026] EWCA Civ 140. The Court ruled that a controller’s data security duty applies to all personal data for which it acts as controller – irrespective of whether the information would constitute personal data in the hands of a third party (in this case, an attacker). Note that the case is concerned with events before the GDPR came into force, so the legal context is provided by UK Data Protection Act 1998 (“DPA 1998”), although the Court did take into account more recent jurisprudence, including CJEU case law.

The case adds useful colour to ongoing debates surrounding the definition of “personal data.” The Court of Appeal confirmed that a controller’s duty to implement appropriate measures to protect personal data applies to data that is “personal” from the perspective of the controller —even if a third-party attacker could not identify individuals from the exfiltrated dataset. This dovetails with the SRB v EDPS’s clarification that whether data is “personal” can depend on the context, while a controller’s obligations (such as transparency) must be assessed from the controller’s perspective at the relevant time (which, for the transparency principle, is at the time of collection of the data). (For more information on SRB v EDPS, see our prior post here.)

Continue Reading UK Court of Appeal Rules on the Concept of Personal Data in the Context of Data Security

On February 18, 2026, the European Data Protection Board (“EDPB”) published its Report on Stakeholder Event on Anonymisation and Pseudonymisation of 12 December 2025 (the “Report”). The Report summarises feedback from a remote stakeholder event convened to inform the EDPB’s ongoing work on Guidelines 01/2025 on Pseudonymisation (version for public consultation available here) and forthcoming guidance on anonymisation. The event gathered input from 115 participants spanning industry, NGOs, academia, law firms, and public sector bodies.

The objective of the Report is to capture stakeholder insights on how the General Data Protection Regulation (“GDPR”) applies to anonymisation and pseudonymisation, particularly following the Court of Justice of the European Union’s (“CJEU”) judgment in EDPS v SRB (C‑413/23 P). (See our previous blog post here.)

Continue Reading EDPB Publishes Report on Stakeholder Event on Anonymisation and Pseudonymisation

On 15 January 2026, the Belgian High Court delivered a judgment in proceedings initiated by the Belgian Supervisory Authority, in which it challenged the scope of judicial review exercised by the Market Court over its enforcement decisions. The authority was unsuccessful on both grounds of appeal.

Continue Reading Belgian High Court Confirms Full Judicial Review of Supervisory Authority Decisions