On 25 November 2020, the European Commission published a proposal for a Regulation on European Data Governance (“Data Governance Act”).  The proposed Act aims to facilitate data sharing across the EU and between sectors, and is one of the deliverables included in the European Strategy for Data, adopted in February 2020.  (See our previous blog here for a summary of the Commission’s European Strategy for Data.)  The press release accompanying the proposed Act states that more specific proposals on European data spaces are expected to follow in 2021, and will be complemented by a Data Act to foster business-to-business and business-to-government data sharing.

The proposed Data Governance Act sets out rules relating to the following:

  • Conditions for reuse of public sector data that is subject to existing protections, such as commercial confidentiality, intellectual property, or data protection;
  • Obligations on “providers of data sharing services,” defined as entities that provide various types of data intermediary services;
  • Introduction of the concept of “data altruism” and the possibility for organisations to register as a “Data Altruism Organisation recognised in the Union”; and
  • Establishment of a “European Data Innovation Board,” a new formal expert group chaired by the Commission.


Continue Reading The European Commission publishes a proposal for a Regulation on European Data Governance (the Data Governance Act)

On July 16, 2019, the UK’s Information Commissioner’s Office (“ICO”) released a new draft Data sharing code of practice (“draft Code”), which provides practical guidance for organizations on how to share personal data in a manner that complies with data protection laws.  The draft Code focuses on the sharing of personal data between controllers, with a section referring to other ICO guidance on engaging processors.  The draft Code reiterates a number of legal requirements from the GDPR and DPA, while also including good practice recommendations to encourage compliance. The draft Code is currently open for public consultation until September 9, 2019, and once finalized, it will replace the existing Data sharing code of practice (“existing Code”).

Continue Reading ICO Launches Public Consultation on New Data Sharing Code of Practice

On 25 May 2018, the EU General Data Protection Regulation (GDPR) came into effect. The GDPR establishes some of the most robust privacy requirements globally and is likely to be a model followed by other jurisdictions. Airlines are uniquely affected by the GDPR with passenger data being at the heart of their business and international operations. As new technologies allow airlines to pursue new and innovative uses of customer data, it is imperative that airlines continue to conduct their operations with GDPR compliance in mind, particularly given the financial and other reputational issues that can arise for a failure to meet the GDPR’s strict requirements.

Below are 5 key issues for airlines to consider in relation to the GDPR post-implementation.
Continue Reading GDPR: Top 5 Post-Implementation Issues for Airlines