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The EU regulation designed to facilitate secondary use of clinical data for research brings benefits for health research, but also poses challenges for companies.

By Deniz Tschammler, Danielle van der Merwe, Oliver Mobasser

On 5 March 2025, Regulation 2025/327 creating the European Health Data Space (the EHDS Regulation) was published in the Official Journal of the European Union and entered into force on 26 March 2025. The European Commission also published FAQs on the European Health Data Space…

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The guidelines specify the requirements for data controllers to conduct risk assessments related to the transfer or disclosure of personal data outside the Kingdom.

By Brian Meenagh, Calum Docherty, Faisal Imam,* and Ksenia Koroleva

The Saudi Data & Artificial Intelligence Authority (SDAIA) has released non-binding guidelines for assessing risks when transferring or disclosing personal data outside the Kingdom (the Guidelines). The Guidelines supplement the updated Regulations on Personal Data Transfer Outside the Kingdom (the Regulations), which were…

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Advocate General Spielmann opines that personal data can be pseudonymous in the hands of one party and anonymous in the hands of another.

By Gail Crawford, Fiona M. Maclean, Myria Saarinen, Tim Wybitul, Isabelle Brams, and Amy Smyth

Advocate General Spielmann (AG) has published his Opinion in the Court of Justice of the European Union (CJEU) case C-413/23 EDPS v. SRB (Opinion), considering various questions on the scope of personal data regulated by the EU…

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The CJEU has decided that the maximum thresholds for GDPR fines should be calculated using the global turnover of the broader corporate group, not solely the infringing entity.

By Gail Crawford, Fiona M. Maclean, Myria Saarinen, Tim Wybitul, Isabelle Brams, and Amy Smyth

The penalties provisions of the EU General Data Protection Regulation (GDPR) include a framework for the calculation of the fines that may be imposed on infringing organisations by national supervisory authorities and…

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Proposals grant controllers increased flexibility for automated decision-making, provided suitable safeguards are implemented.

By Fiona Maclean, Gail Crawford, Amy Smyth, and Lorenzo Meusburger

On 23 October 2024, the UK government introduced the Data (Use and Access) Bill (the Bill) to Parliament, marking a significant step in the evolution of the country’s data protection landscape. It follows previous reform attempts that lapsed after the July 2024 government change. The proposed legislation aims to reform various aspects of UK data protection law while also addressing broader initiatives related to data access and digital identity. Among its many provisions (138 Clauses, 16 Schedules and 251 pages to be precise), the Bill outlines notable changes in the realm of automated decision-making.

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The Regulations, which took effect on January 1, 2025, reiterate and clarify existing requirements and introduce new ones on privacy and network data security.

By Hui Xu and Bianca H. Lee

On September 30, 2024, the PRC State Council released the finalized Regulations on Network Data Security Management (Regulations), concluding a three-year consultation process since the initial draft in 2021.

The Regulations took effect January 1, 2025, and build upon the Cybersecurity Law (CSL), Data Security Law (DSL), and Personal Information Protection Law (PIPL), which form China’s legal framework for data protection and security. The Regulations integrate common cybersecurity requirements from these laws, applying them to “network data processing activities,” which include all electronic data processed through networks.

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The draft guidelines provide further clarification to the EDPB’s interpretation of legitimate interests, and suggest a potential divergence with the UK ICO.

By Gail Crawford, Fiona Maclean, Myria Saarinen, Tim Wybitul, Alice Brunning, and Calum Docherty

On 8 October 2024, the European Data Protection Board (EDPB) released draft Guidelines 1/2024 (the Guidelines) setting out its approach to processing personal data based on the “legitimate interests” legal basis in Article 6(1)(f) of the GDPR. The Guidelines…

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The deadline is fast approaching for in-scope financial entities and their ICT service providers to conform to the EU’s new digital operational resilience regulation.

By Christian F. McDermott and Alain Traill

With effect from 17 January 2025, a broad range of EU financial entities will be subject to the new EU regulation on digital operational resilience for the financial sector (DORA), with significant impact for firms and their third-party ICT service providers. As the new landscape takes shape, below is an overview of some of the key changes and steps that impacted financial entities and providers should be taking ahead of the deadline.

Considerations for UK and US companies that are already or considering relying on the UK-US Data Bridge for personal data transfers.

By Fiona M. Maclean and Clayton Northouse

Latham & Watkins and Privacy Laws & Business recently co-hosted a webinar looking back on the first eight months since the UK-US Data Bridge entered into force. Speakers from the UK Information Commissioner’s Office (ICO) and the US Privacy and Civil Liberties Oversight Board joined the panel for a broad discussion on the practical implementation and future outlook of the UK-US Data Bridge.

Below are key takeaways from the discussion and practical tips for UK and US organisations relying on the UK-US Data Bridge to facilitate personal data transfers to the US from the UK (and Gibraltar) while ensuring data is protected consistent with the standard imposed by UK law.

Covered institutions will need to review their cybersecurity and incident response policies and procedures ahead of the applicable compliance deadline.

By Robert Blamires, Laura Ferrell, Daniel Filstrup, Jennifer Howes, and Sarah Zahedi

The Securities and Exchange Commission (SEC) recently1 adopted amendments to Regulation S-P that expand the scope of requirements applicable to brokers, dealers, investment companies, SEC-registered investment advisers, and foreign (non-resident) SEC-registered brokers, dealers, investment companies, and investment advisers (together, Covered Institutions) in order…