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.
171 articles found · #rgpd
CJEU 19 March 2026 (Brillen Rottler): first access request may be refused for abuse
The CJEU allows a first access request (Art. 15 GDPR) to be refused as “excessive” if an abusive intent is proven (Art. 12(5)). Any refusal must remain exceptional, justified, and within deadlines.
OVG NRW (20 Feb 2025): no general obligation for end-to-end encryption
OVG North Rhine-Westphalia confirms that “appropriate” encryption under GDPR Art. 32 may be limited to robust transport encryption (TLS), depending on risk. How to align legally and technically.
Amazon vs CNPD (12 March 2026): Legitimate interest is not enough
Luxembourg’s Administrative Court annulled the €746M fine but confirmed that behavioral advertising cannot rely on legitimate interest. 2026 takeaways for legal bases and the requirement to prove fault.
DPIA (Art. 35 GDPR) in Luxembourg: when to trigger and how to succeed
When is a DPIA mandatory in Luxembourg and how to do it right? GDPR framework, CNPD list, EDPB method, prior consultation (Art. 36) and best practices.
CNPD — Workplace video surveillance: proportionality, DPIA and employee rights
Workplace cameras are allowed in Luxembourg, but under strict rules: legal basis, proportionality, frequent DPIA, L.261‑1 information duties and employee rights. Document everything, camera by camera.
GDPR – Article 28: the watertight processor contract
In 2026, every DPO/CISO must bulletproof processor contracts. Mandatory clauses, EDPB/CNPD guidance, and a practical audit playbook for a watertight Article 28.
Phishing‑resistant MFA (FIDO2/WebAuthn): answering GDPR Article 32
GDPR Article 32 requires state‑of‑the‑art security. Phishing‑resistant MFA with FIDO2/WebAuthn is the most robust and pragmatic way to comply without unnecessary complexity.
NIS 2 in Luxembourg: Law of 5 May 2026 published—what to do before 10 May
Luxembourg’s law transposing NIS 2 was published on 5 May 2026 and enters into force on 10 May. Broader scope, stronger governance, incident reporting within 24 h/72 h to ILR via SERIMA. Priority actions and official sources.
AI Act – Article 50: transparency for chatbots and deepfakes by 2026
From 2 August 2026, any AI interaction, synthetic content, and any emotion recognition/biometric categorization system must be disclosed. Fines up to €15M or 3% of global turnover.
GDPR Art. 33: Notify CNPD of a breach within 72h—without panic
Practical method, based on official texts and CNPD guidance, to decide, notify, and document a personal data breach within 72 hours.
EU‑US data transfers after Schrems II and the DPF: CNPD expectations 2026
Secure transatlantic flows without over‑compliance: the DPF eases transfers to certified US entities, but Article 46 and supplementary measures remain key outside the DPF. Prioritize vendor governance and DPIA documentation.
CNPD: recording business meetings and conversations in GDPR compliance
In 2026, Luxembourg’s CNPD frames audio/video recording of private meetings. Legal basis, transparency and retention are critical; recordings often must be deleted once the minutes are approved.