On February 13, 2026, France’s highest administrative court (“Conseil d’État”) delivered an important decision clarifying the boundary between pseudonymization and anonymization under the GDPR. The ruling confirms that data which remain re‑identifiable in practice—even with some effort—must be treated as
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AI and Legal Privilege: Key Takeaways from US v. Heppner
On February 10, 2026, federal district court Judge Jed S. Rakoff ruled from the bench in the Southern District of New York that the attorney-client privilege and the work product doctrine did not protect legal strategy materials that a criminal
CISA Releases New Guidance on Assembling Multi-Disciplinary Insider Threat Management Teams
On January 28, 2026, the U.S. Cybersecurity and Infrastructure Security Agency (CISA) published a new resource on Assembling a Multi-Disciplinary Insider Threat Management Team. The guidance is intended to assist critical infrastructure stakeholders, which includes private sector entities across
UK Court of Appeal Rules on the Concept of Personal Data in the Context of Data Security
On February 19, 2026, the UK Court of Appeal handed down its decision in DSG Retail Limited v The Information Commissioner [2026] EWCA Civ 140. The Court ruled that a controller’s data security duty applies to all personal data
CISA Announces Town Halls to Gather Input on CIRCIA Proposed Rule
Earlier this month, the U.S. Cybersecurity and Infrastructure Security Agency (“CISA”) announced a series of public town hall meetings to solicit additional stakeholder input on the Notice of Proposed Rulemaking (“Proposed Rule”) implementing the Cyber Incident Reporting for Critical Infrastructure
EDPB Publishes Report on Stakeholder Event on Anonymisation and Pseudonymisation
On February 18, 2026, the European Data Protection Board (“EDPB”) published its Report on Stakeholder Event on Anonymisation and Pseudonymisation of 12 December 2025 (the “Report”). The Report summarises feedback from a remote stakeholder event convened to inform
Connecticut Attorney General Releases 2025 CTDPA Enforcement Report
The Connecticut Office of the Attorney General (“OAG”) issued an updated Enforcement Report (“Enforcement Report”) under the Connecticut Data Privacy Act (“CTDPA”). The Enforcement Report discusses the OAG’s enforcement actions in 2025 and suggests some areas of focus from the
EU Regulators Issue Opinion on Revisions of GDPR and Other Data Laws
On February 11, 2026, the European Data Protection Board (EDPB) and the European Data Protection Supervisor (EDPS) (jointly, the Authorities) issued a Joint Opinion on the European Commission’s proposed Digital Omnibus Regulation (Digital Omnibus). This follows their Joint Opinion of
International AI Safety Report 2026 Examines AI Capabilities, Risks, and Safeguards
On 3 February 2026, the second International AI Safety Report (the “Report”) was published—providing a comprehensive, science-based assessment of the capabilities and risks of general-purpose AI (“GPAI”). The Report touts itself as the largest global collaboration on AI safety to
Belgian High Court Confirms Full Judicial Review of Supervisory Authority Decisions
On 15 January 2026, the Belgian High Court delivered a judgment in proceedings initiated by the Belgian Supervisory Authority, in which it challenged the scope of judicial review exercised by the Market Court over its enforcement decisions. The authority was