Topic
Data Processing
189 published works
Technology Law Dispatch
European Commission publishes draft Article 28 clauses for consultation
By Philip Thomas, Cynthia O’Donoghue
On 12 November 2020, the European Commission released its first draft set of clauses covering the Article 28 GDPR requirements, for consultation (available here). Article 28 of the GDPR governs…
Data Privacy Dish
Are law firms considered “processors” or “controllers” of the personal data that they collect from third parties as part of a representation of a client?
A law firm will most likely be considered a controller when processing personal data from third parties as part of a representation of a client (e.g., when collecting information from…
Data Privacy Dish
Are barristers and solicitors “separate controllers” or “joint controllers?”
A joint controller is defined within the GDPR as “two or more controllers” that “jointly determine the purposes and means of processing.”[1] There is considerable ambiguity surrounding what it means…
Data Privacy Dish
Are law firms considered “processors” or “controllers” of the personal data that they receive from clients as part of a representation?
By David A. Zetoony, Carsten A. Kociok
It depends. Many lawyers (and clients) incorrectly assume that attorneys must be processors because they are service providers of their clients. In some situations, a service provider has a role…
Data Privacy Dish
What types of information do law firms collect that may be subject to the GDPR?
Law firms typically collect personal data subject to the GDPR in the following five contexts: Employee data. If a law firm has employees in the European Union, the human resource…
Privacy World
What’s New in the EDPB’s Draft Guidelines on Controllers and Processors Under the GDPR? (Part 3)
We continue our series of blog posts on the draft “Guidelines 07/2020 on the concepts of controller and processor in the GDPR” (“draft Guidelines”) issued by the European Data Protection…
Privacy World
What’s New in the EDPB’s Draft Guidelines on Controllers and Processors Under the GDPR? (Part 2)
This is the second in our series of posts on the draft Guidelines 07/2020 on the concepts of controller and processor in the GDPR (the “draft Guidelines”) issued on 7…
Privacy World
What’s New in the EDPB’s Draft Guidelines on Controllers and Processors Under the GDPR? (Part 1)
By Stéphanie Faber, Lucia Hartnett Cabeza
This is the first in a series of posts that discuss the key concepts and issues addressed in a set of draft guidelines recently issued by the European Data Protection…
The Data Advisor
Draft EDPB Guidelines Clarify the Roles of Parties Processing Personal Data and Call for Detailed Data Processing Agreements
By Cédric Burton, Laura Brodahl, Rossana Fol, Lore Leitner
On September 7, 2020, the European Data Protection Board (EDPB) published draft guidelines (Guidelines) intended to clarify the roles of the parties processing personal data and when they are operating…
Inside Privacy
EDPB Publishes Guidelines on the GDPR Concepts of “Controller”, “Joint Controller” and “Processor”
By Dan Cooper, Anna Sophia Oberschelp de Meneses
On September 2, 2020, the European Data Protection Board (“EDPB”) adopted guidelines on the concepts of “controller” and processor” under the GDPR. The Article 29 Working Party had already issued…