UK’s Age Appropriate Design Code Pending

By Josephine Jay, Lore Leitner & Laura Brodahl

November 1, 2019

The Information Commissioner’s Office (ICO) has confirmed that by November 23, 2019, it will present its Age Appropriate Design Code of Practice to the UK Parliament for approval. Unless Parliament objects, this mandatory code will be issued and in force (albeit with a transition period) as early as January 2020. The final code has been hotly anticipated since the call for input on the issue of age appropriate design in June 2018. Since then, the…

The WSGR Data Advisor

ECJ: Cookies Require Active Opt-In Consent

By Bastiaan Suurmond, Josephine Jay & Christopher Foo

October 9, 2019

On October 1, 2019, the European Court of Justice (ECJ) delivered its judgment in Planet49 (C-673/17), holding that (1) website operators must obtain active opt-in consent to store or access cookies, (2) users must be informed about the retention period and the third party receiving the data, and (3) consent must be obtained regardless of whether the cookies contain personal data. This ruling will likely prompt regulators to scrutinize cookie policies and consent…

The WSGR Data Advisor

The ICO Issues Its Cookies Guidance: Clarified Stance and Enforcement Priorities

By Josephine Jay, Lore Leitner & Jan Dhont

July 29, 2019

On July 5, 2019, the UK’s Data Protection Authority (ICO) issued its “Guidance on the use of cookies and similar technologies” (the Guidance) along with a brief explanatory blog post. At the same time the ICO updated its own website cookie notice and consent, leading by example. The ICO’s blog post makes clear that cookie compliance will increasingly be a regulatory priority, and that companies should start working towards compliance now.…

The WSGR Data Advisor

Looking Back: The ICO’s Busy Year and Its Record-Breaking Fines

By Josephine Jay & Lore Leitner

July 18, 2019

The UK Supervisory Authority (the ICO) has had a headline-busting month. On July 9, 2019, the ICO announced its intention to fine Marriott International more than £99 million under the GDPR (General Data Protection Regulation) for a data breach which took place last year,[1] a figure that would have been record breaking had the ICO not announced its intention to fine British Airways £183 million 24 hours earlier.[2] While it is clear that…

The WSGR Data Advisor

The CNIL Announces Its 2019-2020 Action Plan on Ad Targeting

By Cédric Burton, Jan Dhont, Rossana Fol & Josephine Jay

July 10, 2019

On June 28, 2019, the French Data Protection Authority (CNIL) released its 2019-2020 action plan on ad targeting (action plan);1 among other things, the CNIL announced that it will issue new cookie guidance later this month and that, once the guidance is published, companies will have a 12-month grace period to come into compliance. Background When the General Data Protection Regulation (GDPR) became effective on May 25, 2018, it imposed stricter conditions for obtaining…

The WSGR Data Advisor

The ICO Publishes Its Stance on Adtech and Real-Time Bidding

By Cédric Burton, Christopher Olsen, Lore Leitner & Josephine Jay

June 26, 2019

On June 20, 2019, the UK’s Data Protection Authority (ICO) published a report on adtech and real-time bidding. The report highlights the main problems faced by the industry when applying the General Data Protection Regulation’s (GDPR’s) stringent requirements, and calls for further engagement on these issues by the different adtech players in the space. Background When the GDPR became effective on May 25, 2018, it imposed new and strict obligations on companies processing personal data.…

Josephine Jay

UK’s Age Appropriate Design Code Pending

ECJ: Cookies Require Active Opt-In Consent

The ICO Issues Its Cookies Guidance: Clarified Stance and Enforcement Priorities

Looking Back: The ICO’s Busy Year and Its Record-Breaking Fines

The CNIL Announces Its 2019-2020 Action Plan on Ad Targeting

The ICO Publishes Its Stance on Adtech and Real-Time Bidding

Stay Connected

Company

Support

New to the Network