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Thinking - Snapshot

European Data Protection Board adopts statement on age assurance technologies

Published on 10 May 2025. By Oliver Bray, Senior Partner, Technology, Media & Telecoms Sector Lead

How is the European Data Protection Board (EDPB) proposing to address the benefits and risks of age assurance technologies?

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Thinking - Snapshot

New ICO guidance for “consent or pay” online ads

Published on 10 May 2025. By Oliver Bray, Senior Partner, Technology, Media & Telecoms Sector Lead

What is the view of the UK Information Commissioner’s Office (ICO) on whether “consent or pay” online advertising models are compliant with UK data protection law?

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Thinking - Snapshot

Status update on the UK’s new Data (Use and Access) Bill

Published on 10 May 2025. By Oliver Bray, Senior Partner, Technology, Media & Telecoms Sector Lead

The UK’s new Data (Use and Access) Bill (DUA Bill) is on its way, but where is it in the legislative process? And what are proving the sticking points?

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Thinking - Snapshot

Developing responsible GenAI – the UK and EU regulatory view

Published on 10 May 2025. By Oliver Bray, Senior Partner, Technology, Media & Telecoms Sector Lead

What is the UK and EU data protection authorities’ view on ensuring responsible generative AI (GenAI) development and deployment?

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Thinking - Snapshot

High Court rules against Sky Betting’s targeted marketing

Published on 10 May 2025. By Oliver Bray, Senior Partner, Technology, Media & Telecoms Sector Lead

What constitutes valid consent under UK data protection law, particularly in the context of targeted marketing to vulnerable individuals?

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Thinking - Blog

Signed, sealed, (but not) delivered: why email wasn’t enough in Hughes v CSC

Published on 01 May 2025. By Matt Ward, Associate

Whilst notice provisions may not form the basis of commercial negotiations between parties to sale and purchase agreements, failure to consider the practical requirements of these clauses can have stark consequences. In the recent High Court decision of Hughes v CSC Computer Sciences Limited, earn out calculations were found not to have been validly served because they did not comply with contractual notice requirements. This case serves as an important reminder for transaction parties to ensure that notice requirements are carefully complied with.

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Thinking - Blog

PISCES: New platform for intermittent trading of shares in unquoted companies

Published on 10 Apr 2025. By Janice Chan, Senior Associate

The Private Intermittent Securities and Capital Exchange System (PISCES) is a new initiative by the UK government, with support from the Financial Conduct Authority (FCA) and the London Stock Exchange, to enable private company shareholders to trade their shares on an exchange without the company going fully public.

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Thinking - Publication

Part 3 - AI regulation in the US

Published on 03 Mar 2025. By Caroline Tuck, Partner and Praveeta Thayalan, Knowledge Lawyer and Ricky Cella, Senior Associate

Back in October 2022, the White House published federal guidance – a Blueprint for an AI Bill of Rights identifying five principles aiming to guide the design, use, and deployment of automated systems. It was designed to operate as a roadmap to protect the public from AI harms and was followed in October 2023 by the US President's Executive Order on the Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence. The Executive Order sets out eight "guiding principles and priorities", detailing how those principles and priorities should be put into effect, and reporting requirements

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Thinking - Publication

Part 2 - AI regulation in the EU

Published on 03 Mar 2025. By Caroline Tuck, Partner and Praveeta Thayalan, Knowledge Lawyer and Ricky Cella, Senior Associate

The EU AI Act, the main elements of which are covered in our previous article, entered into force on 1 August 2024. Most provisions apply from August 2026 but some apply earlier, or later.

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Thinking - Blog

Model Articles again deemed suitable for sole director companies

Published on 26 Feb 2025. By Rupert Wyles, Senior Associate

A recent decision of the High Court in Re KRF Services (UK) Ltd [2024] EWHC 2978 (Ch) has provided further and stronger authority that the model articles for private companies are suitable for companies with a sole director appointed, clarifying the position following recent cases on this subject.

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Thinking - Blog

Corporate transparency reforms: what comes next?

Published on 20 Dec 2024. By Ella Shanks, Senior Associate

Last year, we reported on the impact of the Economic Crime and Corporate Transparency Act 2023 (the Act), which introduces the biggest changes to Companies House since corporate registrations were established in 1844. Companies House has now issued a transition plan for implementation of the Act, summarising the changes which have already been brought into effect and laying out Companies House's timing expectations for implementation of the remaining updates, including those relating to identity verification.

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Thinking - Snapshot

New Standard Contractual Clauses for data importers outside the EAA but subject to the GDPR

Published on 10 Dec 2024. By Oliver Bray, Senior Partner, Technology, Media & Telecoms Sector Lead

Are the EU’s Standard Contractual Clauses (SCCs) needed if a data importer is located outside the European Economic Area (EEA) and already directly subject to the EU General Data Protection Regulation (EU GDPR)? In other words, where third party controllers and processors are based outside the EAA but subject to the GDPR, do you still need the SCCs to enable a lawful international transfer to them?

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Thinking - Snapshot

The UK’s new Data (Use and Access) Bill

Published on 10 Dec 2024. By Oliver Bray, Senior Partner, Technology, Media & Telecoms Sector Lead

What does the UK’s new Data (Use and Access) Bill (the Data Bill) mean for businesses?

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Thinking - Snapshot

EDPB’s new publications on the ePrivacy Directive, processors and legitimate interests

Published on 09 Dec 2024. By Oliver Bray, Senior Partner, Technology, Media & Telecoms Sector Lead

What are the key takeaways for organisations processing personal data set out in the recent Guidelines and Opinions adopted by the European Data Protection Board (EDPB)?

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Thinking - Snapshot

ICO Statement on Generative AI Model Training

Published on 09 Dec 2024. By Oliver Bray, Senior Partner, Technology, Media & Telecoms Sector Lead

What position does the Information Commissioner’s Office (ICO) continue to take on Generative AI Model training?

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Thinking - Snapshot

ICO reprimands Sky Betting and Gaming for using non-essential cookies without users’ consent

Published on 09 Dec 2024. By Oliver Bray, Senior Partner, Technology, Media & Telecoms Sector Lead

What proactive steps should website operators take to ensure that their use of cookies complies with UK data protection law? Put another way, are you sure personal data is not being collected by your website’s advertising cookies before users have consented to their deployment?

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Thinking - Snapshot

Irish DPC fines LinkedIn €310m for behavioural analysis and targeted advertising breaches

Published on 09 Dec 2024. By Oliver Bray, Senior Partner, Technology, Media & Telecoms Sector Lead

How certain do data controllers need to be of their lawful basis for processing personal data when engaging in behavioural analysis and targeted advertising, and how clearly must this be reflected in a privacy policy?

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Thinking - Blog

Take notice: Court of Appeal reverses High Court decision on validity of notice of warranty claim

Published on 11 Nov 2024. By Rosamund Akayan, Knowledge Lawyer

Last year we reported on the High Court's decision in Drax Smart Generation Holdco Limited v Scottish Power Retail Holdings Limited [2023] EWHC 412 (Comm) that a purchaser's breach of warranty claim under a share purchase agreement (SPA) was time-barred by a clause that required the purchaser to notify its claim before a specified date "stating in reasonable detail the nature of the claim and the amount claimed (detailing the Buyer's calculation of the Loss thereby alleged to have been suffered)".

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Thinking - Blog

Autumn Budget 2024 – Main tax announcements

Published on 04 Nov 2024. By Ben Roberts, Partner and Rachel Stanley, Associate

The Chancellor, Rachel Reeves, delivered the Autumn Budget 2024 on Wednesday 30th October. In doing so, she made the first set of Budget announcements by a Labour Government since 2010. This year's Budget was one of the most eagerly awaited for some time. In terms of the breadth of announcements, it did not disappoint.

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Thinking - Blog

UK National Security Screening: NSIA Annual Report 2023-24

Published on 22 Oct 2024. By Josh Smith, Senior Associate

On 10 September 2024, the Government published its third Annual Report (Report) into the acquisition and investment screening regime established by the National Security and Investment Act 2021 (NSIA), covering the year from 1 April 2023 to 31 March 2024. With very limited information regarding cases reviewed under the NSIA regime being publicly available, the Report provides useful colour and insight around the current application of the regime by the Government's Investment Security Unit (ISU) (which administers the operation of the NSIA) and potential trends.

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Thinking - Snapshot

UK's new AI Cyber Security Code of Practice

Published on 17 Oct 2024. By Oliver Bray, Senior Partner, Technology, Media & Telecoms Sector Lead

What is the UK's proposed AI Cyber Security Code of Practice?

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Thinking - Snapshot

EU AI Act into force 1 August 2024

Published on 17 Oct 2024. By Oliver Bray, Senior Partner, Technology, Media & Telecoms Sector Lead

The EU AI Act came into force across all 27 EU member states on 1 August 2024. The aim of the legislation is to ensure AI systems used in the EU are safe and transparent.

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Thinking - Snapshot

New Minister for Data Protection Sir Chris Bryant

Published on 17 Oct 2024. By Oliver Bray, Senior Partner, Technology, Media & Telecoms Sector Lead

On 8 July 2024, the Government appointed Sir Chris Bryant as the Minister of State for Data Protection and Telecoms (as well as Minister of State for Creative Industries, Arts and Tourism).

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Thinking - Snapshot

Social media and video sharing platforms targeted by ICO over children's privacy practices

Published on 17 Oct 2024. By Oliver Bray, Senior Partner, Technology, Media & Telecoms Sector Lead

What must social technology platforms be aware of to ensure they are following the ICO's codes of practice for children's online safety?

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Thinking - Snapshot

Uber hit with €290m fine for transferring European driver data to its US HQ

Published on 17 Oct 2024. By Oliver Bray, Senior Partner, Technology, Media & Telecoms Sector Lead

What does the Uber fine signal for international data transfers and the consequences of failing to comply with the EU General Data Protection Regulation (EU GDPR)?

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Thinking - Snapshot

X suspends personal data training of AI chatbot Grok following Irish DPC pressure

Published on 17 Oct 2024. By Oliver Bray, Senior Partner, Technology, Media & Telecoms Sector Lead

How are the data regulators addressing the use of personal data when training AI language models?

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Thinking - Snapshot

The UK's new AI Bill

Published on 17 Oct 2024. By Oliver Bray, Senior Partner, Technology, Media & Telecoms Sector Lead

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Thinking - Snapshot

The UK's Digital Information and Smart Data Bill

Published on 17 Oct 2024. By Oliver Bray, Senior Partner, Technology, Media & Telecoms Sector Lead

What can we expect from the new Digital Information and Smart Data Bill (the DISD Bill)?

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Thinking - Publication

Retail Compass Autumn 2024

Published on 02 Oct 2024. By Jeremy Drew, Partner and Karen Hendy, Partner and Ciara Cullen, Partner, Retail & Consumer Sector Lead

Welcome to the autumn edition of Retail Compass. This edition sees a surge of ESG-related legislative and regulatory updates. We hope to guide you through the most pressing, as well as the wider upcoming legal and policy changes affecting retail and consumer brands.

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Thinking - Blog

W&I insurance: Key lessons from recent case law

Published on 22 Aug 2024. By Guinevere Lydia Wentworth, Associate and Charmaine Chew, Senior Associate

Recent case law has highlighted the importance of understanding how a buyer on a share or asset sale has valued the target business and the clear drafting of exclusions. This blog considers the key takeaways for both warranty and indemnity (W&I) insurers and insureds.

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Thinking - Blog

Final UK listing rules: modified transfer process for issuers in transition category

Published on 14 Aug 2024. By Janice Chan, Senior Associate

On 11 July 2024, the FCA published the final UK Listing Rules (UKLR) which came into effect on 29 July 2024 (Implementation Date). The UKLR are broadly in line with the FCA's previous proposals.

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Thinking - Publication

Part 4 – AI Regulation in Asia

Published on 06 Aug 2024. By Nick Lauw, Partner and Pu Fang Ching, Senior Associate and Armani Cheng , Associate

This is Part 4 of 'Regulation of AI – raising the trillion dollar bAIby'

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Thinking - Snapshot

“Consent or pay” models under scrutiny in UK and EU

Published on 01 Aug 2024. By Oliver Bray, Senior Partner, Technology, Media & Telecoms Sector Lead

Are “consent or pay” business models compliant with data protection law?

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Thinking - Snapshot

ICO forces Serco Leisure to stop using facial recognition technology for employees

Published on 01 Aug 2024. By Oliver Bray, Senior Partner, Technology, Media & Telecoms Sector Lead

In what circumstances can facial recognition technology (FRT) be acceptable to monitor employees in the workplace?

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Thinking - Snapshot

Ofcom and ICO to collaborate on Online Safety and Data Protection

Published on 01 Aug 2024. By Oliver Bray, Senior Partner, Technology, Media & Telecoms Sector Lead

How are the data protection and broadcasting regulators collaborating to regulate online services from a safety and privacy perspective, and what does this mean for businesses and services regulated by both bodies?

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Thinking - Snapshot

ICO publishes guidance on content moderation

Published on 01 Aug 2024. By Oliver Bray, Senior Partner, Technology, Media & Telecoms Sector Lead

What steps should businesses operating content moderation systems in the UK be taking to comply with new guidance published by the UK’s Information Commissioner (ICO)?

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Thinking - Snapshot

The ICO’s strategic approach to regulating AI

Published on 01 Aug 2024. By Oliver Bray, Senior Partner, Technology, Media & Telecoms Sector Lead

How can the ICO’s recently published AI strategy paper help businesses navigate the evolving AI regulatory landscape, particularly in respect of data protection principles?

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Thinking - Snapshot

New development: DPDI Bill fails to become law

Published on 01 Aug 2024. By Oliver Bray, Senior Partner, Technology, Media & Telecoms Sector Lead

The Data Protection and Digital Information Bill (DPDIB), the proposal for post-Brexit data protection laws in the UK, did not pass through Parliament before its dissolution on 24 May 2024 ahead of the general election on 4 July 2024. This means that the DPDIB has failed to become law and any proposals for data reform in the UK will largely need to start afresh in the new Parliament.

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Thinking - Blog

AI in Construction

Published on 16 Jul 2024. By Georgina Haynes, Senior Associate

There is a lot of discussion around Artificial Intelligence ("AI") and its application to industry. We have considered what AI is, the benefits and risks, how it fits into the construction industry, the effect on insurers and what the future holds.

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Thinking - Blog

UK listing regime reforms: impact on standard listed issuers

Published on 08 May 2024. By Janice Chan, Senior Associate

Following the FCA's May 2023 consultation on major reforms to streamline and enhance the UK listing regime and its December 2023 publication of detailed proposals, the FCA has now published a consolidated draft UK Listing Rules instrument (UKLR) to replace the current Listing Rules, together with proposed changes to its guidance.

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Thinking - Snapshot

Department for Science, Innovation and Technology consults on proposed data infrastructure statutory framework

Published on 17 Apr 2024. By Oliver Bray, Senior Partner, Technology, Media & Telecoms Sector Lead

What statutory obligations could the Department for Science, Innovation and Technology’s (DSIT) proposed statutory framework impose on UK data centre providers?

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Thinking - Snapshot

ICO publishes updates to its guidance on Transfer Risk Assessments

Published on 17 Apr 2024. By Oliver Bray, Senior Partner, Technology, Media & Telecoms Sector Lead

How will recent updates to the Information Commissioner’s Office’s (ICO) guidance on Transfer Risk Assessments (TRAs) affect how UK organisations conduct their TRAs?

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Thinking - Snapshot

New ICO guidance on content moderation and data compliance

Published on 17 Apr 2024. By Oliver Bray, Senior Partner, Technology, Media & Telecoms Sector Lead

How can organisations using content moderation technologies and processes best comply with data protection laws?

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Thinking - Snapshot

ICO launches consultation series on generative AI and data protection

Published on 17 Apr 2024. By Oliver Bray, Senior Partner, Technology, Media & Telecoms Sector Lead

What is the Information Commissioner’s Office’s (ICO) intended approach to developing guidance on how data protection law should be applied to the development and use of generative AI?

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Thinking - Snapshot

CJEU rules on what constitutes “automated decision-making” under the GDPR

Published on 17 Apr 2024. By Oliver Bray, Senior Partner, Technology, Media & Telecoms Sector Lead

Does the production of a credit score constitute “automated decision-making” for the purposes of Article 22 of the EU General Data Protection Regulation (GDPR)? What wider impact will this have for AI technologies?

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Thinking - Snapshot

EDPB adopts opinion on “main establishment” of a controller in the EU

Published on 17 Apr 2024. By Oliver Bray, Senior Partner, Technology, Media & Telecoms Sector Lead

What is meant by “main establishment” under article 4(16)(a) of the GDPR for the purposes of determining the application of the one-stop-shop mechanism?

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Thinking - Snapshot

ICO warns UK’s most visited websites to improve cookie choices

Published on 17 Apr 2024. By Oliver Bray, Senior Partner, Technology, Media & Telecoms Sector Lead

What steps is the ICO taking to ensure that website cookie banners are compliant with law?

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Thinking - Snapshot

New Development: EU Data Act published in Official Journal

Published on 17 Apr 2024. By Oliver Bray, Senior Partner, Technology, Media & Telecoms Sector Lead

The EU Data Act (the Act) came into force on 11 January 2024. The Act sets out rules regarding the fair access to and use of data, aiming to enhance the data economy for individuals and businesses by overcoming barriers to data sharing and establishing frameworks around data access and use.

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Thinking - Snapshot

ICO fines HelloFresh £140,000 after 7-month spam marketing campaign

Published on 17 Apr 2024. By Oliver Bray, Senior Partner, Technology, Media & Telecoms Sector Lead

Where did HelloFresh go wrong with their email and text marketing campaign and what lessons can be learned from the ICO’s investigation and subsequent fine?

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Thinking - Publication

Retail Compass Spring 2024

Published on 15 Apr 2024. By Jeremy Drew, Partner and Karen Hendy, Partner and Ciara Cullen, Partner, Retail & Consumer Sector Lead

Welcome to the Spring edition of Retail Compass, where we guide you through key upcoming legal and policy changes affecting retailers and consumer brands and provide our thoughts on those crucial, need-to-know issues.

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