In message <[log in to unmask]>, at
23:42:56 on Wed, 15 Jun 2016, Michael Bacon - Grimbaldus
<[log in to unmask]> writes
>"... if the manner in which the consent has been given is in line with
>the conditions of this Regulation ..."
>
>And therein lies the rub. What is meant by "manner"? If that covers
>the inclusion of the requirements of Art 13, few current FPNs or online
>Privacy Policies cover that ground, and the proviso won't be satisfied
>and surely then, re-consent will be required to legitimise continued
>processing
That's the way I'd read it too. viz: "If your policies would be legal
under the new directive, you don't have to renew the consent".
Conversely, no grandfather rights for consent obtained in ways which
would infringe the new directive.
--
Roland Perry
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