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GDPR Contracts and Liabilities Between Controllers and Processors

On 13 September, the Information Commissioner’s Office (ICO) published draft guidance on GDPR contracts and liabilities on contracts between controllers and processors under the GDPR (the “Guidance”).  The ICO is consulting on the Guidance until 10 October.  We summarize the key aspects of the Guidance below.… Continue Reading

Data Localization Requirements Through the Backdoor? Germany’s “Federal Cloud”, and New Criteria For the Use of Cloud Services by the German Federal Administration

In May 2015, reports about the German government’s plans to establish federal German cloud infrastructure (the “Bundes-Cloud”) raised concerns about the possible introduction of data localization requirements (preventing the storage and processing of data outside Germany).  The criteria for the use of cloud services by Germany’s federal administration, which have recently been published, now give … Continue Reading

Implications of the FTC Report and DOC Green Paper for IT Contracts

We have previously blogged on the FTC’s privacy report on “Protecting Consumer Privacy in an Era of Rapid Change” and the Department of Commerce’s Green Paper on “Commercial Data Privacy and Innovation in the Internet Economy: A Dynamic Policy Framework.”  We have also published client alerts on the FTC report and the DOC green paper.  … Continue Reading
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