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.
40 articles found · #edpb
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.
72 hours or a fine: the Mayor of Myślenice flagged — a reminder for Luxembourg
On 25 May 2026, Poland’s UODO fined the Mayor of Myślenice for failing to notify a data breach within 72 hours (GDPR Art. 33). A useful reminder of what the CNPD expects in Luxembourg.
Transfers to the United States: CNPD implements the DPF, EDPB remains cautious
The CNPD confirms “free” transfers to US entities certified under the DPF (Art. 45 GDPR), while the EDPB maintains reservations and calls for ongoing vigilance.
CNPD 1FR/2025: how the DPA calculates a GDPR fine in 5 steps
On 6 January 2025, the CNPD fined a controller for delays in data subject rights and applied the EDPB’s five-step method. Key takeaway: track and document your “time-to-rights”.
GDPR Article 6: the Poste Italiane fine clarifies legitimate interest vs consent
Italy’s DPA fined Poste Italiane/PostePay €12.5m for intrusive device access via apps without a valid legal basis. Key message: anything beyond what is strictly necessary often requires valid consent, not legitimate interest.
Workplace video surveillance: the Hanako case rules out consent
Italy’s Garante (12/03/2026) fined Hanako s.r.l. for in-store video surveillance without proper notice and labor authorization. EU-wide message: in employment, employee consent is not a convenient legal basis.
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.
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.
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.
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.
CNPD 16/12/2025: insufficient GDPR Article 30 record sanctioned
On 16/12/2025, the CNPD imposed a €7,000 fine for an incomplete Article 30 record. The decision clarifies required fields (recipients, transfers, categories, retention, security) and the EDPB fine calculation method.