Breaking down Article 37(1)(b) key terms: 'core activities', 'regular', 'systematic', 'monitoring' and 'large scale'. And what should you do if you're still unsure whether you need to appoint a DPO? Appoint one voluntarily?
NB: On 9 July, CNIL appears to have updated the webpage with that date, though there don’t seem to be any actual changes – and the PDFs are still from January. Either way, here’s a quick reminder! 💬 "CNIL TIA template is one of the best templates available to the public!"
IMY has shared a DPIA guide, primarily for those with little or no experience. It sets out a clear 10-step process for conducting an "acceptable" DPIA, to be used alone or with their templates. Grab the documents here (Swedish and DeepL translation).
The 🇳🇱 DPA issued new guidelines for the private sector (public sector one coming) on web scraping, stating it's "almost always illegal", and reiterates their highly controversial claim that ❌ You can't rely on legitimate interest for purely commercial reasons... 🤨
🇩🇰 DPA changes sub-processor third-party beneficiary clause in their SCCs for data processing agreements as per Article 28(8). Agreements signed before this are still valid.