Schrems II Heard In Europe: Potential Huge Impact On Global Data Transfers

The General Data Protection Regulation ("GDPR") will enter into force 25 May 2018, and will provide new general data protection standards.

The UK's Information Commissioner's Office has completed its supervision of major AI foundation model developers, revealing significant gaps in data protection practices and setting new expectations for legitimate interests assessments, transparency, and special category data handling. The regulator has now turned its attention to agentic AI systems, warning that autonomy is not an excuse for poor compliance and launching a call for evidence that will shape future regulatory guidance.

The European Data Protection Board has published draft guidelines proposing a fundamental shift in GDPR enforcement: a presumption that fines should be imposed for non-minor infringements, with a deliberately low bar for establishing negligence. Organizations will need to demonstrate robust compliance programs and documented decision-making to potentially avoid penalties, as regulators move from asking "should we fine?" to "can we justify not fining?"

The UK's Information Commissioner's Office has launched a six-week consultation on agentic AI systems, examining how data protection law applies to autonomous AI agents that can make decisions and take actions with minimal human oversight. The call for evidence focuses on six critical themes including data security, transparency, accountability, automated decision-making, fairness and purpose limitation, and lawful bases for processing personal data.

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The UK Information Commissioner's Office has finalized its guidance on storage and access technologies, expanding compliance requirements beyond traditional cookies to include tracking pixels, device fingerprinting, and web storage. Organizations must now navigate stricter consent standards and three new narrow exceptions introduced by the Data (Use and Access) Act 2025, while facing significantly increased enforcement penalties of up to £17.5 million or 4% of annual worldwide turnover.

From 2 August 2026, the EU AI Act requires businesses to disclose when people are interacting with AI systems, mark synthetic content for detection, label deepfakes, and inform individuals...

On 30 September 2026, the Information Commissioner's Office formally becomes the Information Commission. It is the most significant structural change to the UK's data protection regulator in its history, and yet, many organisations are wondering what practical implications this change will have. Here's what you need to know.

Domestic surveillance technology has evolved from simple security cameras to sophisticated smart systems that may inadvertently create legal obligations for homeowners. When does a Ring doorbell or CCTV system transform an ordinary citizen into a data controller subject to UK GDPR, and what are the implications of millions of private cameras forming an unregulated surveillance network?

The Data (Use and Access) Act 2025 (the DUAA) officially became law in June 2025, with a phased enforcement model under which different provisions take effect at different times.