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.
CSSF 25/903: Support PSF — the inventory/CMDB as key evidence
CSSF 25/903 strengthens 24/850 and requires structured evidence on support PSF ICT organization. An automated inventory/CMDB becomes central to trace assets, dependencies and controls, and to meet NIS 2 obligations.
Data transfers outside the EU: EDPB vs ICO — essential equivalence or risk test?
On 15 Jan 2026, the ICO introduced a simplified three‑step test and TRA, diverging from the EDPB/CNPD’s ‘essential equivalence’ plus supplementary measures approach. Bottom line: distinct compliance tracks for EU vs UK transfers.
European Commission: Europa.eu breach — how a CSPM prevents the next one
On March 27, 2026, the European Commission confirmed data exfiltration from its cloud hosting Europa.eu. Here’s how a CSPM evidences compliance (GDPR Art. 32, CSSF 22/806) and prevents a repeat.
Workplace video surveillance: DPIA before any camera (Coccaglio)
Italy’s Garante fined the Comune di Coccaglio €6,000 for employee video surveillance without a credible DPIA and for disciplinary use of footage. In Luxembourg, a prior DPIA is almost always required when employees may be captured.
Ernst & Young: support ticket data leak — DLP for GDPR Art. 32 and cross‑border transfers
In July 2026, EY confirmed fraudulent access to a third‑party ticketing tool with tax documents downloaded. Here is a practical DLP to curb exfiltration and evidence GDPR compliance (Art. 32 and 44‑49).
GDPR Record: CNPD fines for insufficient ROPA, ICO promotes flexibility
On 16 December 2025, the CNPD fined an organisation for an “insufficient” record of processing (Art. 30 GDPR). By contrast, the ICO updated a more flexible approach in June 2026. This gap affects EU–UK groups.
NIS 2: LAUNDRY BEAR/NCSC 'beehive' targets Zimbra
NCSC and partners expose “LAUNDRY BEAR”: a zero‑click campaign against Zimbra. This is the email stack (SEG + DMARC/SPF/DKIM) and NIS 2 actions to reduce risk and notify properly.
Vehicle geolocation in Luxembourg: CNPD requirements 2024
On 10 April 2024, the CNPD updated its guidelines: no continuous tracking or outside working hours, DPIA often required, retention generally 2 months, and obligations under Labour Code L. 261‑1.
Coca‑Cola/Fairlife: ransomware, production halt and data theft
Coca‑Cola confirms data theft following a ransomware attack against Fairlife. U.S. production was suspended mid‑July; the Anubis group claims up to 1 TB of data.
CSSF 26/906: strengthened governance and risk — an ISO 27001 ISMS to evidence NIS 2
CSSF 26/906 tightens governance and risk for payment/e-money institutions, with compliance due by 30 June 2026. A certified ISO 27001 ISMS operationalizes these requirements and NIS 2 Article 21.
CNPD: recording private meetings — legitimate interest only under conditions
CNPD finds consent rarely valid in meetings and allows legitimate interest only after a strict necessity and balancing test. Recordings must be deleted as soon as minutes are approved.
Garante vs Lusha: €2M fine for data brokering without legal basis
Italy’s Garante fined Lusha €2,000,000 for collecting/selling professional contacts without a legal basis and adequate information. A strong signal for the use of data enrichment tools in the EU.