The first impression of this leaked text is that this version of the
Regulation is more prescriptive than Directive 95/46/EC and will get up most
data controllers and Governmental noses. I think the text makes far too many
fundamental changes than can be reasonably done via a Regulation (which has
three times as many Articles as the Directive it replaces). And this
conclusion is from someone who thinks changes to the UK data protection
regime are badly needed (see references).
I think this text is open to the argument that the Regulation is so long
that it should be discussed as a new Directive which can be debated by
Member States and national Parliaments; this ensures ...
If interested go to http://amberhawk.typepad.com/amberhawk/
C
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