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.
Google Groups abused: Lumma Stealer/Ninja Browser campaign
CTM360 warns of a campaign abusing Google Groups to deliver Lumma (Windows) and “Ninja Browser” (Linux). NIS 2-aligned controls, DMARC/SPF/DKIM, and an email security gateway are advised.
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.
NIS 2 Luxembourg: 5 May 2026 law published, ILR self-registration window until 10 July 2026
Luxembourg's 5 May 2026 law transposing the NIS 2 directive entered into force on 10 May. Essential and Important Entities must self-register with the ILR by 10 July 2026.
EDR/XDR: Continuous detection aligned with NIS 2 (Art. 21) and DORA (Art. 10)
Executives must demonstrate continuous and effective incident detection. A well‑deployed EDR/XDR stack meets NIS 2 Art. 21 and DORA Art. 10 requirements with auditable technical evidence.
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.
Automated patching: the answer to NIS 2, Article 21
Executives must prove vulnerabilities are remediated in a timely manner. Well-configured automated patching is the safest, most auditable way to meet NIS 2 Art. 21.
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.
Cloud CSPM: the answer to CSSF Circular 22/806 on outsourcing
To remain compliant with CSSF in 2026, moving to the cloud is not enough. A CSPM continuously proves correct configuration, monitoring, and auditability as required.
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.
TLPT (threat‑led red team): meeting DORA Articles 26‑27
DORA requires selected financial entities to run threat‑led penetration tests on production systems. This is how a structured TLPT implementation fulfils Articles 26‑27, step by step.