Patrice Navarro

Firm/Organization: Hogan Lovells

Blogs: Global Media and Communications Watch, HL Chronicle of Data Protection

Latest Articles

New French Guidelines on Cookies and Trackers

By Patrice Navarro on July 23, 2019

On 19 July the French Data Protection Authority (the “CNIL”) published new guidelines on cookies and trackers. These replace the existing Recommendation No. 2013-378 of 5 December 2013, are intended to be in line with relevant GDPR provisions and have been produced in anticipation of the future ePrivacy Regulation. The guidelines will be supplemented, at a later stage, with sectoral recommendations setting out practical methods for obtaining consent. These sectoral recommendations will be included in…

HL Chronicle of Data Protection

New French Guidelines on Cookies and Trackers

By Patrice Navarro on July 22, 2019

HL Chronicle of Data Protection

The French Data Protection Authority Gets Ahead of the Game With New Rules on Cookie Consent Before the ePrivacy Regulation Reaches its Final Draft

By Patrice Navarro on July 8, 2019

The French Data Protection Authority (the CNIL) has made targeted online advertising a priority topic in its 2019-2020 agenda and has changed its position on cookie consent. Although the ePrivacy Regulation is still being debated by EU legislators and is far from being finalised, the CNIL has withdrawn its 2013 cookie recommendation and announced that it will publish new guidelines (announcements are available in English on the CNIL’s website here and here). These explicitly…

Global Media and Communications Watch

EDPB’s Position on Clinical Trials Creates Friction with Other EU Legislation

By Patrice Navarro & Elisabethann Wright on May 1, 2019

Clinical trials in the EU include the collection of sensitive health data from patients. Trial sponsors are obliged to reconcile their respect of regulations governing data protection with regulations governing the conduct of clinical trials. The GDPR¹ could not fully harmonize these rules since this area is already heavily regulated by public health regulations that vary between EU Member States. One of the most disconcerting areas of divergence between EU Member States is the different national…

HL Chronicle of Data Protection

EDPB’s Position on Clinical Trials Creates Friction with Other EU Legislation

By Patrice Navarro & Elisabethann Wright on April 25, 2019

HL Chronicle of Data Protection

French Data Protection Authority’s Latest Newsletter Includes Assessment of First Four Months of GDPR & Several Guidelines

By Patrice Navarro & Winston Maxwell on October 11, 2018

The French Data Protection Authority (the CNIL) published its assessment of the first four months of GDPR and several guidelines, including one on how to make a GDPR compliant blockchain. The CNIL just published its latest newsletter (n°14, dated 25 September 2018) with: initial results of its factual assessment of the implementation of the EU General Data Protection Regulation (GDPR) in France and in Europe; and interesting developments about its latest series of…

HL Chronicle of Data Protection

GDPR Is In Effect: The French Bill Has Been Adopted…But Referred to the French Constitutional Council

By Winston Maxwell, Patrice Navarro & Mathilde Gérot on May 25, 2018

The General Data Protection Regulation (GDPR) entered into force on 25 May 2018. In light of the urgency to adapt Law no. 78-17 dated 6 January 1978 to the new European Union law, the French Government has initiated an accelerated procedure. This procedure led to the adoption in final reading by the French National Assembly of the bill on personal data protection on 14 May 2018. However, some French Senators lodged a constitutional complaint against the said…

Global Media and Communications Watch

One day before the entry into force of the GDPR, the French bill is adopted… but referred to the French Constitutional Council (“Conseil Constitutionnel”)

By Winston Maxwell, Patrice Navarro, Mathilde Gérot & Anne-Laure Morise on May 24, 2018

The General Data Protection Regulation (GDPR) will enter into force on 25 May 2018. In light of the urgency to adapt Law no. 78-17 dated 6 January 1978 to the new European Union law, the French Government has initiated an accelerated procedure. This procedure led to the adoption in final reading by the French National Assembly of the bill on personal data protection on 14 May 2018. However, some French Senators lodged a constitutional complaint against the said law on…

Global Media and Communications Watch

Hosts of health data: certified compliant!

By Winston Maxwell, Patrice Navarro & Charles-Henri Caron on March 6, 2018

The Decree No 2018-137 of 26 February 2018 on the hosting of personal health data has been published on 28 February 2018 in the Official Journal. The Decree defines notably the arrangements for implementing the procedure for certifying hosts of health data. Context The Decree has been adopted pursuant to Order No 2017-27 of 12 January 2017 on the hosting of personal health data which substantially modified Article L1111-8 of the French Public Health Code…

Global Media and Communications Watch

French National Assembly Votes to Align the CNIL’s Sanctioning Powers with the GDPR

By Patrice Navarro & Matthieu Richard on February 17, 2016

While organizations in the EU will have to get used to the possibility of receiving fines of up to 4% of total worldwide annual turnover when the General Data Protection Regulation (GDPR) comes into force in roughly 2 years’ time, organizations in France should prepare for higher sanctions sooner. A bill, passed by the French National Assembly on 26th January 2016, and now before the French Senate, would amend Article 47 of the French Data Protection Act…

Patrice Navarro

New French Guidelines on Cookies and Trackers

New French Guidelines on Cookies and Trackers

The French Data Protection Authority Gets Ahead of the Game With New Rules on Cookie Consent Before the ePrivacy Regulation Reaches its Final Draft

EDPB’s Position on Clinical Trials Creates Friction with Other EU Legislation

EDPB’s Position on Clinical Trials Creates Friction with Other EU Legislation

French Data Protection Authority’s Latest Newsletter Includes Assessment of First Four Months of GDPR & Several Guidelines

GDPR Is In Effect: The French Bill Has Been Adopted…But Referred to the French Constitutional Council

One day before the entry into force of the GDPR, the French bill is adopted… but referred to the French Constitutional Council (“Conseil Constitutionnel”)

Hosts of health data: certified compliant!

French National Assembly Votes to Align the CNIL’s Sanctioning Powers with the GDPR

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