Spring has seen a deluge of data protection developments.
Key points to note are:
- Two CJEU decisions:
(1) Ruling the Data Retention Directive unlawful; and
(2) On the Google case – confirming a right to be forgotten against search engines and giving guidance on applicable law;
- The Article 29 Working Party have released several documents and opinions, including important positions on anonymisation and reliance on legitimate interests; and
- The UK Government has signalled that it will consult on lowering the threshold for PECR monetary penalties to "nuisance and annoyance" from "substantial damage and distress".
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