Articles, by our experts

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.

EDPB — Scientific research: last chance to comment

On 25 June 2026, the EDPB closes its public consultation on Guidelines 1/2026 for processing personal data for scientific research. Key clarifications on legal basis, broad consent, and GDPR Article 89 safeguards.

AEPD fines Yoti €950,000 — Automated DPIA becomes essential

On March 10, 2026, the AEPD fined Yoti €950,000 for unlawful biometrics, invalid consent and excessive retention. A tooled, automated DPIA is now key to reduce risk and evidence GDPR compliance.

Information duty (Art. 14 GDPR): the legal exception clarified in 2026

The French Court of Cassation (Jan 29, 2026) confirms the Art. 14(5)(c) GDPR exception where a law mandates disclosure and provides appropriate safeguards. Useful for tax/social flows and certain B2G sharing in Luxembourg.

Evidence and personal data: France’s Supreme Court draws a clear line

On 17 June 2026, the French Supreme Court allowed an analysis report based on pseudonymised data as evidence, where necessary and strictly proportionate. A green light for carefully run internal investigations.

Outsider Enterprise dismantled: urgent need for phishing‑resistant FIDO2 MFA

FBI, Google, and Black Lotus Labs dismantled “Outsider Enterprise,” a PhaaS linked to >1M URLs and ≈$1.9B in losses. Why FIDO2/WebAuthn MFA is now the “appropriate measure” under GDPR Article 32.

Ex-employee mailbox: €176,000 fine and a short-lived legitimate interest

Belgian DPA (Decision 101/2026): keeping an ex-employee’s mailbox active for over a year is unlawful. Legitimate interest only covers a very short redirection (~1 month), with transparency, LIA and offboarding procedures.

AI Act: Code of Practice signing — D‑41 before your AI labels

On 22 June 2026, the Commission unveiled the Code of Practice for labelling AI-generated content. Transparency duties (Art. 50) apply from 2 August 2026, with penalties for non-compliance.

CSSF — Axios compromised (31/03/2026): EDR/XDR to detect and notify under DORA

The CSSF warns about the Axios supply‑chain compromise and reminds firms to notify a major ICT incident under Circular 25/893 (DORA). Here is how an EDR/XDR stack helps detect, contain, and notify on time.

IQVIA fined €5M: pseudonymisation ≠ anonymisation

The CNIL fined IQVIA €5M over shortcomings in two health data warehouses. Key takeaway: pseudonymised data are still personal data and the GDPR applies in full.

ENISA 2026: Separate, tested backups aligned with DORA

ENISA updates its SME guide: backups separated from production, encrypted and end-to-end tested. How immutable, isolated vaults meet DORA Art. 12 and thwart ransomware.

GDPR Article 28: Belgian DPA fines SWDE — your DPA must be rock-solid

On 12 May 2026, the Belgian DPA fined SWDE €86,000, including €1,000 for lacking an Article 28-compliant DPA. Key takeaway: without a complete DPA, any outsourced processing leaves the controller non-compliant.

Novo Nordisk rejects $25M after 1.3 TB data theft

On June 16, 2026, FulcrumSec claimed to have stolen over 1 TB from Novo Nordisk and demanded $25M. The company confirmed a June 11 incident, is investigating, and did not pay.