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GDPR: Alumni processes

Most universities maintain databases of alumni, for purposes including keeping them informed about the organisation, offering services and seeking donations. These activities have a lot in common with other charities, so the Information Commissioner’s guidance is relevant. Indeed the Information Commissioner’s recent description of using consent-based relationships “to improve [supporters’] level of engagement with your […]

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Article 29 Working Party support security and incident response

Having had my own concerns that the European Commission’s draft e-Privacy Regulation might prevent some activities that are needed by security and incident response teams, it’s very reassuring to see the Article 29 Working Party recommending an explicit broadening of the scope of permitted Network and Information Security (NIS) activities. Strikingly, this comes in an […]

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ePrivacy Regulation: a risk for website security?

Last October the European Court of Justice confirmed that websites do have a legitimate interest in security that may justify the processing of personal data. That case (Breyer) overruled a German law that said websites could only process personal data for the purpose of delivering the pages requested by users. As far as I know, […]

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Privacy online: is a separate Directive still needed?

Now that the General Data Protection Regulation has been completed, the European Commission is reviewing the ePrivacy Directive. This law was introduced in 2002 as part of the telecommunications framework, and it was recognised at the time that it was likely to be largely replaced by a future general privacy law. That has taken longer […]

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Art.29WP on Cookies – specific and pragmatic advice

The e-Privacy Directive’s provisions on cookies exempt two classes of cookies from the requirement to gain consent (though if they relate to individual users, websites still need to inform users about them, under data protection law): CRITERION A: the cookie is used “for the sole purpose of carrying out the transmission of a communication over […]

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ENISA on cyber incident reporting

ENISA have  published an interesting report on cyber incident reporting. Their scope is wide – incidents range from the failure of a certificate agency to storms creating widespread power (and therefore connectivity) outages. In each of these areas they find a common pattern, where governments are trying to encourage (or mandate) notification of incidents in […]