Digital Economy Bill changes "personal data" definition and increases risk
of an inadequacy determination
Just published on Hawktalk: <http://amberhawk.typepad.com/amberhawk>
http://amberhawk.typepad.com/amberhawk
A new definition of "personal data" (the one most likely to be applied in
the UK's version of the GDPR) can be found in the new clauses (Clauses
112-115) just incorporated into Digital Economy Bill (DEB), now in its final
Parliamentary stages. It is unlike the current definition of "personal
data" in the Data Protection Act (DPA).
However, the Clauses that allow Ministers to establish the new notification
fees regime also run the risk of being interpreted in a way that will fail
to meet the European Commission's test of adequacy, needed by the UK, in its
brave new Brexit world.
This blog covers the new definition of "personal data" and explains how the
proposed notification fees regime adds to the risks of a negative adequacy
determination.
If interested, go to blog
Chris
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