UK & EU Data Protection Bulletin: May - July 2016

By Ruth Boardman, Ariane Mole


Welcome to the May – July edition of our UK & EU data protection bulletin.

The highlights this month are:

  • Privacy Shield Updates: In July 2016, the European Commission formally adopted a decision confirming the adequacy of Safe Harbor's replacement – the EU-U.S. Privacy Shield, addressing a number of concerns raised by the Article 29 Working Party earlier in 2016. However, the Working Party issued a statement in response to the revised Privacy Shield, stating that a number of its original concerns remained. Further coverage on the Privacy Shield, including the Opinion of the European Data Protection Supervisor, can be found inside.
  • Implications of Brexit: On 23 June 2016, the UK electorate voted to leave the European Union. The ICO's annual report was published on 28 June and the Information Commissioner, Christopher Graham, confirmed that the ICO would be discussing with the Government the implications of the referendum result and its impact on data protection reform in the UK.
  • Status of IP addresses as Personal Data: In May, the Attorney General delivered his Opinion in the Patrick Breyer v Federal Republic of Germany case, concluding that dynamic IP addresses qualify as personal data insofar as additional information held by the internet provider allows for identification of the visitor. To read our full article on this, please click here.

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