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 fines 2026: direct actions opened against EDPB decisions
On 10/02/2026, the CJEU allowed companies to bring direct actions against the EDPB’s “binding” decisions. The fine calculation method (Art. 83 GDPR) and compliance orders can now be challenged before the EU courts.
AEPD fines Amadeus €14.4M for traveler profiling without legal basis
Spain’s AEPD fined Amadeus IT Group €14.4M (reduced from €18M) for a traveler profiling pilot using booking data without a lawful basis and without informing travelers. Decision made public on May 26–27, 2026.
Tycoon 2FA: device code campaign bypasses Microsoft MFA
On May 12, 2026, eSentire detailed a Tycoon 2FA campaign abusing the OAuth Device Code flow to steal tokens without passwords. Why phishing-resistant FIDO2/WebAuthn MFA is required to meet GDPR Article 32.
CNPD frames meeting recordings: divergence with the CNIL
As of 01/04/2026, the CNPD tightens meeting audio: strict legitimate interest and deletion once minutes are approved. In France, the CNIL allows call recording for evidential purposes but bans audio paired with CCTV.
French Supreme Court (Mar 5, 2026) reshapes qualified e-signatures
Since March 5, 2026, only a Qualified Electronic Signature (QES) shifts the burden of proof. How to evidence QTSP, QSCD and LTV to secure contracts and compliance.
Intra-group sharing: CNIL accepts legitimate interest, CNPD treats it as a transfer
In Luxembourg in 2026, legitimate interest may ground intra-group administrative sharing, but the CNPD qualifies it as a transfer between controllers, requiring strong transparency and, outside the EEA, a Chapter V mechanism.
AI Act: 3 days to respond — EU consultation on transparency
The European Commission closes its consultation on transparency guidelines (Article 50 AI Act) on 3 June 2026. Last call to finalize your “AI” notices and labelling of synthetic content.
Luxgap SealedMail: the first email server where your CIO cannot read you
Launch of SealedMail, zero-knowledge email server hosted in Luxembourg, designed for executives. End-to-end encryption with X25519 asymmetric keys. Neither IT admin nor Luxgap can read your mailboxes. Works with your usual Outlook.
DORA: West Pharmaceutical, why immutable backups are vital
On 4 May 2026, West Pharmaceutical suffered a ransomware attack with data theft and encryption, halting manufacturing and shipping. Here is the backup architecture that prevents prolonged outages and meets DORA.
Ireland — Permanent TSB fined: GDPR arts. 32/33 tested at call centers
The Irish DPC fined Permanent TSB €277,500 for call center authentication failures and late notification. Lesson for Luxembourg: Article 32 and the 72h rule (Art. 33) also apply to human processes.
CNIL updates MR‑001/MR‑003: an operational playbook (26/05)
The CNIL updates MR‑001 and MR‑003 and releases compliance checklists. Immediate effect for health research conducted in France, impacting Luxembourg sponsors when French patients or sites are involved.
NIS 2 Art. 23: Instructure/Canvas, 275M users, 24/7 SOC
ShinyHunters breached Instructure/Canvas, threatening up to 275M records. How a managed SOC/SIEM enables 24h qualification and ILR notification under NIS2 Art. 23.