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
CNIL: New Guidelines on Tracking Pixels in Emails
The CNIL releases guidelines and FAQs to regulate tracking pixels in emails, affecting companies using tracking tools. A key priority for DPOs and CISOs across Europe.
IQVIA: €5m fine and health data — Article 9 GDPR under strain
CNIL fines IQVIA France €5m for failings in health data warehouses. Key takeaway for Luxembourg: “pseudonymised” data remains health data (Art. 9 GDPR) and requires a strict legal basis and effective safeguards.
France Travail: €5M fine for inadequate security (GDPR Art. 32)
On 22 January 2026, the CNIL fined France Travail €5M for breaches of GDPR Article 32. Key takeaway: prove the proportionality and effectiveness of security measures, with clear documentation, including in Luxembourg.
Workplace video surveillance: CNPD (8 days) vs CNIL (1 month)
The CNPD sets an 8‑day retention period “in principle,” while the CNIL allows up to one month. A concrete divergence affecting retention, DPIAs and employee information.
Workplace video surveillance: CNIL fine of 2 April 2026
On 02/04/2026, the CNIL imposed a €7,500 fine for CCTV non-compliance. In Luxembourg, the CNPD likewise requires proportionality, frequent DPIAs and two-layer information.
CNIL: vehicle location data — new recommendation
On 30 June 2026, the CNIL issued a recommendation on the use of vehicle location data. It clarifies ePrivacy consent, multi-user rights, security, data minimisation and the need for DPIAs.
Recording meetings and calls: €250,000 fine — CNPD framework 2026
On 16/10/2025, the CNIL fined a call center €250,000 for poorly governed recordings. Since April 2026, the CNPD has issued a dedicated framework for meeting recordings: legal basis, transparency, retention, security, and DPIA.
Mandatory DPIA: CNPD vs CNIL — geolocation, two thresholds
In Luxembourg, the CNPD requires a DPIA for any systematic tracking of location. In France, the CNIL only mandates it for large-scale processing of location data.
Cold calling: Constitutional Council ends the triple risk
On 25 June 2026, France’s Constitutional Council struck down parallel CNIL/ARCOM/DGCCRF proceedings for the same electronic marketing (Art. L.34‑5 CPCE). Repeal by 31 Oct 2027, but immediate effect: no more duplicate proceedings.
IQVIA fined €5M: pseudonymisation ≠ anonymisation
The CNIL fined IQVIA €5M over shortcomings in two health data warehouses. Key takeaway: pseudonymised data are still personal data and the GDPR applies in full.
France Travail fined €5M: GDPR Article 32 moves from theory to audit
The CNIL fined France Travail €5M for breaches of GDPR Article 32: security measures identified in the DPIA but not implemented. A clear signal for Luxembourg organizations.
GDPR: complaint closure and no Article 78 appeal if not concerned
The French Council of State (20 May 2026) held that a CNIL complaint closure is not a “legally binding decision” triggering an Article 78 GDPR appeal if the complainant is not concretely affected.