A recent decision by the Austrian Supervisory Authority (“SA”) casts a spotlight on the complexities of data transfers and cookie use, and highlights a shift in regulatory focus onto these topics in the year ahead. Regulators around Europe are increasingly beginning to weigh in on such transfers, and the outcomes of their deliberations will shape the data transfer compliance landscape in the months to come. These decisions present complex questions about the future of data transfers in the EU and UK.
Continue Reading Increased EU Scrutiny of US Data Transfers Through Cookie Use

There were 887 million reasons why one GDPR story was dominating the press on Friday. But sneaking under the radar was a decision from the English High Court that I reckon should be more interesting to businesses in the UK.
If French is the language of love (Italians: don’t @ me), and music is a universal tongue, where does that leave English? Besides the obvious and universally loved cultural touchstones (Charles Dickens, Alfred Hitchcock, Alan Partridge), it’s also become the lingua franca for privacy notices.
An interesting article in today’s FT on the need to update the GDPR will not be welcomed by those that toiled with compliance programs, policy updates and the preparation of records of processing less than three years ago.
Since passage of the California Consumer Privacy Act (“CCPA”) and California Privacy Rights Act (“CPRA”), many states have proposed data protection bills that have floundered in the legislative process. Virginia, previously a dark horse in the race amongst US states to pass data protection legislation, is now poised to take the lead with the
The European Court of Justice this morning issued a significant – and fairly surprising – ruling on international data transfers in the Schrems II case. Standard contractual clauses remain valid, but the Privacy Shield is invalid and cannot be relied on to legitimise transfers of personal data from the EEA to the US.