Unpacking compliance, security and AI.
Our DPOs and CISOs regularly share their take on regulatory and technical news here: new CNPD guidelines, notable sanctions, incident lessons learned, evolutions on the AI Act, NIS 2 and DORA. To go beyond the press release.
GDPR Article 28: when a vendor is a processor (AEPD SEUR/Citibox)
On 8 June 2026, the AEPD fined SEUR and Citibox for lacking a GDPR Article 28-compliant data processing agreement in a “carrier + smart lockers” setup. Contract labels are not decisive; actual processing reality prevails.
CJEU: age checks for foreign porn sites, under conditions
On 16 June 2026, the CJEU conditionally upheld requiring porn sites based in another EU state to implement age checks. A strong signal for regulators like ARCOM with immediate GDPR implications.
Shai-Hulud: supply-chain token theft — why FIDO2 MFA is non-negotiable
Zscaler documents “Shai-Hulud”: GitHub/npm/PyPI compromises, OIDC abuse, and public IOCs. Phishing-resistant FIDO2/WebAuthn MFA addresses GDPR Article 32 and blocks initial access.
GDPR: complaint closure and no Article 78 appeal if not concerned
The French Council of State (20 May 2026) held that a CNIL complaint closure is not a “legally binding decision” triggering an Article 78 GDPR appeal if the complainant is not concretely affected.
AI Act: Code of Practice published — D-46 for your AI notices
On 10 June 2026, the Commission published a Code of Practice for marking/labelling AI-generated content. From 2 August 2026, transparency obligations (Art. 50) apply. Sign and implement this week.
DSG Retail v ICO Broadens the Security Duty: Serious DLP Required
The English Court of Appeal confirms a broadened security duty: anticipate jigsaw identification. Here is how ISO 27001‑aligned DLP meets GDPR Article 32.
Free Mobile/Free fined €42M: lessons for your 72h GDPR response
CNIL fines Free Mobile (€27M) and Free (€15M) after a breach affecting 24M contracts. Priorities: security (Art. 32), content of authority notifications (Art. 33) and of communications to individuals (Art. 34).
Munich: Google held liable for false “AI Overviews”
On May 28, 2026, the Munich I Regional Court barred Google from publishing false claims via “AI Overviews,” deeming them Google’s “own statements,” with penalties of up to €250,000 per breach.
AUR compromised: 400+ Arch Linux packages push an eBPF rootkit
On June 12, 2026, over 400 AUR packages were used to distribute an infostealer with an eBPF rootkit. Here’s how an EDR/XDR stack helps detect it quickly and meet NIS 2 and DORA requirements.
AI Act — Prohibited practices (Art. 5): the Commission’s 2025 clarifications
On 4 February 2025, the Commission issued guidelines on prohibited AI practices (Art. 5 AI Act). Eight uses are banned as of 02/02/2025, with fines up to €35m or 7% of global turnover.
ILR — NIS 2 Incident Notification: 24h to alert
On 5 May 2026, Luxembourg transposed NIS 2. ILR released guidance with a 24h early warning, 72h notification and a 1‑month final report. Here is how a managed SOC/SIEM helps meet these milestones calmly.
CNPD vs CNIL: workplace CCTV, 8 days in LU, up to 30 days in FR
The CNPD sets a default retention of “up to 8 days,” while the CNIL in practice admits up to one month. Entities operating in Luxembourg must adjust their practices and records.