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Greek Supervisory Authority imposes fines on controller and processor arising from same incident
11 September 2025 Noteworthy decision from the Greek Supervisory authority who fined both the data controller and data processor arising from the same incident. The controller was found to have infringed its obligations to select a suitable data processor and supervise them effectively. This case highlights the need for a robust vendor managements programme from onboarding assessments to contracts and DPAs and ongoing due diligence. See EDPB for further details: https://www.e

Elaine Morrissey
Sep 11, 20251 min read
Fixing the Data Processing Agreement (DPA) process: seven years of lessons learned
10 September 2025 How to improve the DPA process Introduction While we are 7 years into DPAs being a requirement for both processors and controllers under the EU General Data Protection Regulation (GDPR), they are still causing bottlenecks and can impact the overall execution of master services agreements or contracts if not managed appropriately. This article seeks to look at some of the bottlenecks and how to overcome them. Article 28 GDPR As per Article 28 of the GDPR (Art

Rock Consultancy
Sep 10, 20254 min read
EU AI Act milestone: GPAI, National Authorities, Governance, confidentiality and penalties
2 August 2025 Summertime milestone leaves no time for novels by the beach Intro 2 August (while Irish people enjoy the August bank...

Elaine Morrissey
Aug 22, 20253 min read
DPOs and DPC’s Annual Report 2024
July 2025 Being a Data Protection Officer (DPO) is no easy task, and there have been many learnings and challenges during the last seven years. The learnings apply to both the DPO and the organisations they work with to understand the role and how that role best fits within the organisation. The opening line of the DPO section of the DPC Annual Report of 2024 sums up the importance of the DPO role: "The role played by organisational Data Protection Officers (DPOs) is critical

Elaine Morrissey
Jul 28, 20252 min read
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