IT Security & Privacy

BaFin President Mark Branson used a keynote speech to signal a strategic recalibration of German financial supervision toward greater proportionality, simplified rules, and faster, risk-focused intervention, particularly for troubled institutions. Compliance teams should note the emphasis on governance and risk culture over pure quantitative metrics, as well as expanded supervisory resources in cybersecurity, AML, conduct supervision, and forensic investigations. This signals heightened scrutiny of firms with weak governance structures, dominant management figures, or non-core business activities.

The Data Protection Commission has fined the Health Service Executive EUR 645,000 following an inquiry into systemic failures in the storage and retention of paper records containing sensitive medical data, triggered by two 2023 breach notifications. The decision underscores that GDPR security and storage-limitation obligations apply equally to physical records as to digital systems, and highlights breach notification and data subject communication failures as separately sanctionable infringements. Compliance teams, especially in healthcare and other sectors managing legacy paper archives, should treat this as a warning to audit offsite and legacy storage facilities.

The Dutch Data Protection Authority has completed its mandatory GDPR Article 36(4) legislative review of the draft Data Governance Regulation Implementation Regulation and raised no objections. This clears a key regulatory checkpoint for the decree's progression, signaling that the Dutch government's approach to implementing the EU Data Governance Regulation aligns with GDPR principles and fundamental rights protections.

The Dutch Data Protection Authority (DPA) reviewed a draft regulation on the Smoking Cessation Programme Scheme and identified a single but significant deficiency: the draft fails to specify which categories of personal data healthcare providers must exchange when declaring mutually provided services. This matters for compliance teams because it reinforces the DPA's consistent expectation that any legal basis permitting data sharing, particularly data touching on health information, must meet strict legal certainty standards under GDPR.

The Netherlands Data Protection Authority (AP) has reviewed the draft Regulation on the Experiment in Rehabilitation and Recovery Care (NR/REG-2701) under Article 36(4) GDPR and raised no objections. While this is a sector-specific healthcare regulation, it illustrates the AP's assessment framework for evaluating proportionality and data protection safeguards in draft legislation, which is instructive for compliance teams managing GDPR-related legislative consultations.

The FCA has published findings from its Defence, Security, and Resilience (DSR) Lab, a joint exercise with the Ministry of Defence that tested firms' preparedness for systemic, sector-wide shocks such as satellite spoofing, subsea cable damage, and cyberattacks on critical infrastructure. While not formal guidance or a statement of regulatory obligations, the update signals growing supervisory focus on shared dependencies and national resilience, and provides a self-assessment framework compliance teams should use proactively.

A gambling operator in Croatia offered its casino customers a shortcut. Instead of producing an identity card on every visit, players could use an RFID chip or their fingerprints to identify themselves more quickly. For 34,933 players, consent to biometric processing was recorded. But when Croatia’s Personal Data Protection Agency examined how that system actually worked, it found that the operator was collecting more than it said it was collecting.