On May 25, 2018, Europe's General Data Protection Regulation
("GDPR") went into effect with the aim of standardizing
data protection laws for businesses that, among other things,
collect, retain and/or use the personal data of European Union
("EU") residents. Businesses across the world are trying
to determine what impact the GDPR data rules will have on their
operations. Larger companies, such as Google and Facebook, are
already facing GDPR compliance challenges: multi-billion-dollar
lawsuits have been filed against some companies for allegedly
forcing consumers to consent to the collection of their personal
data for targeted advertising purposes.
Over time, the enforcement of the GDPR will become more
predictable and businesses will get more comfortable with the data
collection and use restrictions imposed by the GDPR. However, in
the first few days following the GDPR's effective date, there
are still several questions surrounding the scope of
enforcement. One of
