Navigating Compliance: Key Insights From FDPIC Recent Investigations

Although the investigations were initiated before the revised Federal Act on Data Protection Act (FADP) came into force in September 2023 and were therefore conducted under the previous law, some of the conclusions deserve special attention and can serve as an indicator of the expected requirements for data protection compliance under the revised FADP.

This article does not address or evaluate the individual recommendations of the Federal Data Protection and Information Commissioner (FDPIC). It also does not address the arguments of the companies under investigation, which in most respects contradict the assessment and recommendations of the FDPIC. Instead, it summarises the key messages and findings based on the data protection audit conducted by the FDPIC, which are also relevant under the applicable law.