Following a wave of “session replay” wiretapping lawsuits in the United States, France’s Commission Nationale de l’Informatique et des Libertés (CNIL) has launched a consultation on tools for recording and replaying browsing...more
In the context of a significant increase in data breaches and cyber-attacks impacting hospitals, the French Data Protection Authority (“CNIL”) has launched a series of investigations and issued several formal notices to...more
The French Data Protection Authority launches a public consultation on location data of connected vehicles, until May 20, 2025. This work will shape future regulations regarding the use of location data and its impact on...more
In 2024, the CNIL stepped up its enforcement action, issuing 87 sanctions, 180 compliance orders and 64 reprimands. However, only 12 decisions were made public, thus complicating the exercise of making the regulator’s...more
Finding a European consensus around the regulation of artificial intelligence (AI) does not start with the adoption of laws. It results from their common interpretation and articulation within a broader digital regulatory...more
While mobile apps have become one of the major means of access to digital services, their ubiquity is accompanied by significant risks to users' privacy, due to the massive amount of personal data they collect and process....more
On January 31, 2025, the French supervisory authority (CNIL) published the final version of its guide on transfer impact assessments (TIA). A TIA must be undertaken by organisations relying on one of the ‘appropriate...more
The CNIL has published its strategic plan for the period of 2025-2028. This is typical of the CNIL, who regularly inform its stakeholders of its priorities....more
App permissions do not satisfy the requirements for valid consent for the purpose of GDPR because they lack sufficient detail and granularity, according to the Commission Nationale de l’Informatique et des Libertés (CNIL)....more
Anticipating enforcement priorities of regulators may partly rely on their long-term trajectory and domestic dynamics, which differ from a country to another. This action plan reflects CNIL’s ambition (i) to be appointed by...more
Recent decisions by the French data protection authority (CNIL) have highlighted the importance of GDPR compliance, particularly in the areas of data retention, consent for processing sensitive personal data, and marketing...more
As the Paris 2024 Summer Olympic and Paralympic Games (the “Games”) turn onto the final straight, the Games have yet again captured widespread global attention, on and off the track. With over 15.3 million visitors in Paris...more
On July 9, 2024, the CNIL launched a public consultation on a draft recommendation (“Draft Recommendation”) on measuring diversity in the workplace. While measuring diversity is an important indicator in the fight against...more
On May 16, 2024, the CNIL announced a critical public consultation and three significant updates to adapt health research regulations in France. These updates, focusing on remote quality control, home monitoring, and...more
Il n’y a pas de question plus difficile en matière contentieuse que celle de l’anticipation des risques de faire l’objet d’un contrôle ou d’une sanction. C’est la raison pour laquelle il est utile de se nourrir des évolutions...more
The CNIL’s newly released recommendations for AI system developers set out the regulator’s expectations for the entire development process of an AI system, from design to database creation and integration, ensuring...more
Each year, the CNIL selects key areas of high interest to concentrate its investigations and assess the compliance of select commercial sectors. On February 8, The CNIL announced its four main areas of focus for...more
The CNIL has launched an investigation into a significant data breach affecting over 33 million individuals in France, involving third-party payment operators Viamedis and Almerys. It is the biggest breach in France involving...more
Following the publication of several press articles and employee complaints, the French data protection regulator (“CNIL”) carried out an investigation at the Amazon France Logistique’s (“Amazon”) warehouses. The CNIL's...more
On January 8, 2024, the CNIL launched a public consultation on a draft guide (Draft Guide) covering Transfer Impact Assessments (TIA). Under GDPR, as interpreted by the Court of Justice of the European Union (CJEU) and...more
The French Data Protection Authority announced a €600,000 fine against Groupe Canal+ over concerns with the media company’s direct marketing activities. According to the CNIL, the company sent users email marketing without...more
On 16 October 2023, France’s Data Protection Authority, the National Commission on Informatics and Liberty (CNIL), issued a set of guidelines for complying with the EU General Data Protection Regulation (GDPR) when...more
French authorities have fined an air freight company for a string of employee data violations, and for its failure to fully cooperate with their investigation....more
The French Data Protection Authority (the "CNIL") has just published two new reference methodologies for research, studies, or evaluations necessitating access to the data in the French Healthcare database. These new...more
On October 12, 2023, the CNIL released its first guidance on how to comply with the General Data Protection Regulation (GDPR) when developing and using artificial intelligence (AI) using personal data or impacting...more