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.

25 articles found · #cnil

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).

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.

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.

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.

Health data: €5M fine against IQVIA — what GDPR Article 9 really requires

On May 26, 2026, the CNIL fined IQVIA €5M over shortcomings in its health data warehouses. The case illustrates GDPR Article 9’s general prohibition and the strict conditions of its exceptions.

DPIA: EDPB template (Apr 2026) and CNPD/CNIL divergences

The EDPB issued an EU DPIA template for consultation (April 2026). Yet CNPD and CNIL still diverge on triggers, with France publishing a “not required” whitelist that Luxembourg does not.

France Travail fined: key lessons from GDPR Article 32

On 22 January 2026, the CNIL fined France Travail €5M for weaknesses in authentication, logging and access rights. In Luxembourg, GDPR Article 32 requires appropriate, demonstrably effective security measures.

French Council of State — Beaucaire (Apr 30, 2024): the CNIL bar for IAM

France’s Council of State confirms CNIL’s password guidance as state of the art to assess GDPR Article 32. Robust IAM governance enables compliance by design.

Analytics cookies: CNIL/CNPD exemptions, ICO still requires consent

On 29 April 2026, the ICO confirmed that non-essential analytics cookies require PECR consent. In France and Luxembourg, CNIL and CNPD allow narrow exemptions for certain audience measurement cookies.

External DPO France: why choose a Luxembourg firm recognised across Europe

French company looking for an external DPO? Discover the advantage of a Luxembourg European-scale firm: multi-regulator knowledge (CNIL, CNPD, APD, BfDI, AEPD, Garante), pluridisciplinary team, lower cost than Parisian firms.

Criteo: France’s Conseil d’État upholds €40M — consent prevails in AdTech

On 4 March 2026, France’s Conseil d’État upheld the €40M fine against Criteo for personalized advertising without valid consent. Key takeaway in AdTech: for targeting trackers, the lawful basis is (almost always) consent.

CNIL 2025 report: EUR 487M in fines, 1 breach in 2 = hacking, key takeaways

CNIL 2025 annual report: 20,150 complaints (record), EUR 487M in fines (including Google EUR 325M and Shein EUR 150M), 1 breach in 2 results from hacking. The real signal for 2026 and 4 concrete actions for DPO and CISO.

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