What does this cover?

On 16 November the Luxembourg Presidency produced a briefing note to the Permanent Representatives Committee in advance of the 8th trilogue discussions which took place on 24 November. The intention of the note was to identify the areas of focus for the discussions. The following items are addressed as some of the main outstanding issues where further input is required:

  • Consent
  • Purpose limitation
  • Sensitive Data
  • Icons
  • Information to the Data Subject
  • Right to be Forgotten
  • Right to Object to Profiling
  • Data Breaches
  • Data Protection Officers
  • International Transfers  

The key points to be decided are the ones that have been 'parked' during previous trilogue discussions and they remain some of the most important aspects of the GDPR to be agreed upon. The production of a final version of the GDPR by the end of the year largely depends upon these major aspects of the GDPR, and given the number of issues still undecided, the 'Christmas' deadline Albrecht, as often referred to, looks more and more unlikely.

What action could be taken to manage risks that may arise from this development?

None - this is for interest only.

Submitted by Aldo Feliciani of Studio Legale Bonarae Associati – Milan, Italy in partnership with DAC Beachcroft.