In three-month time, the General Data Protection Regulation (GDPR), will become applicable to many, if not all, data processing activities to which living individuals can be associated. Businesses operating in Europe have had about two years to prepare for this change. As readers know, even if the GDPR is a lengthy piece of … Continue reading
Category Archives: big data
big data / Consumer data / GDPR / Legitimate interest / metadata / Privacy impact assessment / pseudonymisation
EU Article 29 Working Party consults on draft guidance on automated decision-making and profiling
“Computer says ‘No’”? …So, what exactly do the regulators think that the GDPR says in response? Last month, the Article 29 Working Party (Art.29 WP) announced that it is seeking feedback on draft Guidelines on automated individual decision-making including profiling (WP251) under the General Data Protection Regulation ((EU) 2016/679) (GDPR) in advance of its arrival … Continue reading
big data / Data protection / data protection agencies / General Data Protection Regulation / Privacy impact assessment / Risk-based approach / sensitive data
New EU Guidelines on Data Protection Impact Assessments
Assessing the likelihood of a ‘deep impact’ – but how ‘deep’ is ‘deep enough’ and by whose standards? In other words, how exactly do you develop a methodology for determining whether processing is “likely to result in a high risk” to data subjects under the GDPR? Draft guidelines on conducting data protection impact assessments (DPIAs) … Continue reading
Anonymisation, pseudonymisation, WiFi tracking and the French: the JCDecaux case
The topic of ‘anonymisation’ has already been covered several times on the blog (see e.g. here, here, and here). We even have a new research paper (‘Anonymous Data v. Personal Data — A False Debate: An EU Perspective on Anonymization, Pseudonymization and Personal Data’) recently published in the Wisconsin International Law Journal on this issue … Continue reading
anonymisation / big data / Data protection / General Data Protection Regulation / ICO / Personal data / Privacy / pseudonymisation / research / Risk-based approach / sensitive data
The First-Tier Tribunal and the anonymisation of clinical trial data: a reasoned expression of Englishness…. which would have to be abandoned with the GDPR?
The Queen Mary University of London v (1) The Information Commissioner and (2) Alem Matthees, EA/2015/0269 case decided by the First-Tier Tribunal (Information Rights) (FTT(IR)) on 12 August 2016 is a fascinating decision. [Could it be a stylish expression of Englishness…. or otherness?] The case-facts concern a freedom of information request for clinical trial patient data … Continue reading
anonymisation / big data / Data protection / General Data Protection Regulation / Internet intermediaries / metadata / pseudonymisation / Risk-based approach / Surveillance
Mind the Caveats – CJEU Advocate General opines that Dynamic IP Addresses can be Personal Data … (sometimes)
“I am not a number …” – but to what extent does EU data protection law deem that I am identifiable from one if someone somewhere could link it back to me at a single point in time? The Court of Justice of the EU (CJEU) has been hearing arguments in a case involving the … Continue reading
anonymisation / big data / Data protection / General Data Protection Regulation / Geo-location data / Personal data / Privacy / Privacy impact assessment / pseudonymisation
Location Data and Making Sense of the Goldilocks Paradox of Legal Anonymisation (too much, too little or just right…?)
Collect, delete, repeat …. From ‘Where I am’ to ‘Who I am’, and back again? To pick up the thread from my previous posts on the topic of location data here and here, this final piece in the set returns to the first theme I discussed. This relates to the legal debate over when location … Continue reading
anonymisation / big data / Data protection / data protection agencies / European Data Protection Supervisor / General Data Protection Regulation / ICO / Privacy / pseudonymisation / Risk-based approach
The GDPR and the biggest mess of all: why accurate legal definitions really matter….
Issued last week, here is what seems to be the final version of the General Data Protection Regulation (the GDPR)! This 6 April 2016 version, likely to be adopted by the European Parliament this week, is now in the kiosks! HIP HIP HOORRAY I hear you thinking, either ironically because more than 4 years of … Continue reading
anonymisation / big data / Data protection / General Data Protection Regulation / Personal data / pseudonymisation / research / sensitive data
What does the agreed version of the GDPR say about processing personal data for research purposes? Is the GDPR better than the Directive?
What does the agreed version of the GDPR say about processing personal data for research purposes? Is the GDPD better than the Directive? So here we are. It’s almost Christmas and after three years of intense debate the Council of the European Union and the European Parliament have announced that they have informally agreed on … Continue reading
Businesses engaged in ‘big data’ personal data processing should consider carefully whether they have ‘legitimate interests’ grounds to justify their activities, says ICO
How exactly should data controllers carry out a ‘balance of interests’ test between their interests and the interests of data subjects? The application of data protection rules to big data technologies raises a number of legal and compliance issues, some of which I highlighted in my recent post about the latest comments from the Information … Continue reading