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Thinking - Blog

The EU's Cyber Resilience Act: 10 on the 10

Published on 10 Dec 2024. By Richard Breavington, Partner and Dorian Nunzek, Associate

Today the EU's Cyber Resilience Act (Regulation (EU) 2024/2847) ('CRA') enters into force. The CRA recognises that the continuously evolving world of smart products is frequently challenged by vulnerabilities which can potentially lead to cyber-security incidents. Whilst most of the Act's obligations will not be applicable until three years from now, 10 December is the day when the EU takes a big step towards it's ten-year Cybersecurity Strategy. To mark the occasion, we have outlined ten key points that entities in scope must be aware of in preparation for compliance with the CRA.

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Thinking - Blog

New Data (Use and Access) Bill

Published on 26 Nov 2024. By Jon Bartley, Partner and Praveeta Thayalan, Senior Knowledge Lawyer

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

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Thinking - Blog

Changes to the One Stop Shop

Published on 09 Oct 2023. By Richard Breavington, Partner

In July 2023 the European Commission issued a Proposal for a Regulation of the European Parliament and of the Council laying down additional procedural rules relating to the enforcement of Regulation (EU) 2016/679 (the 'GDPR' Regulations).

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Thinking - Snapshot

ICO publishes guidance on compliance of game design with the Children’s Code

Published on 31 Mar 2023. By Oliver Bray, Senior Partner, Technology, Media & Entertainment Sector Lead

What steps can game designers take to ensure their games comply with the Children’s Code?

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Thinking - Blog

RPC Law x Web3: Gambling regulations – Don't Play Games of Chance with the Law

Published on 22 Feb 2023. By Nick Lauw, Partner and Pu Fang Ching, Senior Associate

This is part of a series of RPC x Web3 articles designed to help Web3 participants and enthusiasts understand their rights in this rapidly evolving space.

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Thinking - Snapshot

Snapshots Autumn 2025

Published on 21 Nov 2025. By Oliver Bray, Senior Partner, Technology, Media & Entertainment Sector Lead and David Cran, Partner, Head of Disputes

Our Autumn 2025 roundup of key legal developments for the modern commercial lawyer.

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Thinking - Snapshot

CJEU clarifies when pseudonymised data counts as personal data in third‑party transfers

Published on 17 Nov 2025. By Oliver Bray, Senior Partner, Technology, Media & Entertainment Sector Lead

When does pseudonymised data qualify as personal data in the context of transfers to third parties under the GDPR?

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Thinking - Snapshot

ICO launches consultation on DUAA’s new recognised legitimate interest

Published on 17 Nov 2025. By Oliver Bray, Senior Partner, Technology, Media & Entertainment Sector Lead

Why does the Information Commissioner’s Office (ICO) consultation on recognised legitimate interest (RLI) draft guidance matter, and what should organisations be doing now?

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Thinking - Snapshot

EU’s Digital Omnibus initiative aims to simplify rules on data, cyber-security and AI

Published on 17 Nov 2025. By Oliver Bray, Senior Partner, Technology, Media & Entertainment Sector Lead

How will the European Commission’s Digital Omnibus initiative simplify legislation on data, cybersecurity, and artificial intelligence for businesses?

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Thinking - Snapshot

The EU Data Act is live: how will SaaS, PaaS and IaaS providers be affected by new early termination and switching provisions?

Published on 17 Nov 2025. By Oliver Bray, Senior Partner, Technology, Media & Entertainment Sector Lead

What are the implications of the EU Data Act’s provisions on SaaS, PaaS and IaaS?

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Thinking - Snapshot

UK ICO’s risk-based approach to online advertising and cookie consent

Published on 17 Nov 2025. By Oliver Bray, Senior Partner, Technology, Media & Entertainment Sector Lead

How is the ICO proposing to adopt a more risk-based, proportionate approach to online advertising regulation - particularly around cookies - while maintaining privacy safeguards?

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Thinking - Snapshot

UK Data (Use and Access) Act comes into force

Published on 23 Sep 2025. By Oliver Bray, Senior Partner, Technology, Media & Entertainment Sector Lead

What are the key elements of the UK’s new Data (Use and Access) Act (DUAA)?

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Thinking - Snapshot

ICO publishes new guidance on anonymisation and pseudonymisation

Published on 23 Sep 2025. By Oliver Bray, Senior Partner, Technology, Media & Entertainment Sector Lead

What are the ICO's latest key recommendations for effective anonymisation and pseudonymisation of personal data?

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Thinking - Snapshot

Encryption under scrutiny: what the ICO’s new guidance means for your business

Published on 23 Sep 2025. By Oliver Bray, Senior Partner, Technology, Media & Entertainment Sector Lead

What is the ICO's current thinking around encryption practices where organisations are subject to the UK GDPR?

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Thinking - Snapshot

€530m TikTok fine highlights the importance of effective international data transfer mechanisms

Published on 23 Sep 2025. By Oliver Bray, Senior Partner, Technology, Media & Entertainment Sector Lead

What were the missing compliance elements in TikTok's international data transfers to China and why did these result in such a significant fine?

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Thinking - Snapshot

Snapshots Summer 2025

Published on 23 Sep 2025. By Oliver Bray, Senior Partner, Technology, Media & Entertainment Sector Lead and David Cran, Partner, Head of Disputes

A roundup of key legal developments for the modern commercial lawyer.

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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 & Entertainment 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 - 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 & Entertainment 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 & Entertainment 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

European Data Protection Board adopts statement on age assurance technologies

Published on 10 May 2025. By Oliver Bray, Senior Partner, Technology, Media & Entertainment 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 & Entertainment 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

Snapshots Spring 2025

Published on 09 May 2025. By Oliver Bray, Senior Partner, Technology, Media & Entertainment Sector Lead and David Cran, Partner, Head of Disputes

A roundup of key legal developments for the modern commercial lawyer.

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Thinking - Snapshot

Snapshots Winter 2024

Published on 10 Dec 2024. By Oliver Bray, Senior Partner, Technology, Media & Entertainment Sector Lead and David Cran, Partner, Head of Disputes

A roundup of key legal developments for the modern commercial lawyer.

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Thinking - Snapshot

Snapshots Autumn 2024

Published on 17 Oct 2024. By Oliver Bray, Senior Partner, Technology, Media & Entertainment Sector Lead and David Cran, Partner, Head of Disputes

A roundup of key legal developments for the modern commercial lawyer.

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Thinking - Snapshot

Snapshots Summer 2024

Published on 01 Aug 2024. By Oliver Bray, Senior Partner, Technology, Media & Entertainment Sector Lead and David Cran, Partner, Head of Disputes

A roundup of key legal developments for the modern commercial lawyer.

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Thinking - Snapshot

Snapshots Spring 2024

Published on 17 Apr 2024. By Oliver Bray, Senior Partner, Technology, Media & Entertainment Sector Lead and David Cran, Partner, Head of Disputes

A roundup of key legal developments for the modern commercial lawyer.

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Thinking - Snapshot

Snapshots Winter 2023

Published on 12 Dec 2023. By Oliver Bray, Senior Partner, Technology, Media & Entertainment Sector Lead and David Cran, Partner, Head of Disputes

A roundup of key legal developments for the modern commercial lawyer.

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Thinking - Snapshot

Snapshots Autumn 2023

Published on 25 Oct 2023. By Oliver Bray, Senior Partner, Technology, Media & Entertainment Sector Lead and David Cran, Partner, Head of Disputes

A roundup of key legal developments for the modern commercial lawyer.

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Thinking - Snapshot

Snapshots Summer 2023

Published on 07 Jul 2023. By Oliver Bray, Senior Partner, Technology, Media & Entertainment Sector Lead and David Cran, Partner, Head of Disputes

A roundup of key legal developments for the modern commercial lawyer.

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Thinking - Snapshot

Snapshots Spring 2023

Published on 31 Mar 2023. By Oliver Bray, Senior Partner, Technology, Media & Entertainment Sector Lead and David Cran, Partner, Head of Disputes

A roundup of key legal developments for the modern commercial lawyer.

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Thinking - Snapshot

Snapshots Winter 2022

Published on 23 Dec 2022. By Oliver Bray, Senior Partner, Technology, Media & Entertainment Sector Lead and David Cran, Partner, Head of Disputes

A roundup of key legal developments for the modern commercial lawyer.

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Thinking - Blog

It's a wrap! Highlights from the ICO DPPC 2025

Published on 25 Nov 2025. By Praveeta Thayalan, Senior Knowledge Lawyer and Cavan Fabris, Partner, Head of Data & Cyber

The ICO held its annual Data Protection Practitioners' Conference (DPPC) on 14 October. With a packed agenda, eminent speakers and over 7,000 data protection professionals in attendance, it was one of the highlights of the privacy lawyer's year. Here we set out the key messages we took away from the conference.

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Thinking - Publication

Cyber_Bytes - Issue 77

Published on 14 Nov 2025. By Richard Breavington, Partner and Daniel Guilfoyle, Partner and Rachel Ford, Partner and Ian Dinning, Senior Associate and Christopher Ashton, Senior Associate and Elizabeth Zang, Associate and Emanuele Santella , Associate and Lauren Kerr, Associate

Welcome to Issue 77 of Cyber_Bytes, our regular round-up of key developments in cyber, tech and evolving risks.

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Thinking - Publication

Cyber_Bytes - Issue 76

Published on 24 Sep 2025. By Richard Breavington, Partner and Daniel Guilfoyle, Partner and Rachel Ford, Partner and Ian Dinning, Senior Associate and Christopher Ashton, Senior Associate and Elizabeth Zang, Associate and Emanuele Santella , Associate and Lauren Kerr, Associate

Welcome to Issue 76 of Cyber_Bytes, our regular round-up of key developments in cyber, tech and evolving risks.

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Thinking - Snapshot

Ofcom publishes children's online safety codes and risk assessment guidance

Published on 23 Sep 2025. By Oliver Bray, Senior Partner, Technology, Media & Entertainment Sector Lead

What measures must in-scope service providers undertake following the introduction of Ofcom's Protection of Children Codes and Guidance (the Codes)?

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Thinking - Snapshot

New UK Software Security Code of Practice

Published on 23 Sep 2025. By Oliver Bray, Senior Partner, Technology, Media & Entertainment Sector Lead

What impact will the new voluntary Software Security Code of Practice have on UK organisations?

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Thinking - Snapshot

Navigating the AI Act: The GPAI Code of Practice and Guidelines

Published on 23 Sep 2025. By Oliver Bray, Senior Partner, Technology, Media & Entertainment Sector Lead

What does the European Commission’s GPAI Code of Practice and Guidelines mean for providers of General Purpose AI models?

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Thinking - Snapshot

First fines issued under the EU Digital Markets Act

Published on 23 Sep 2025. By Oliver Bray, Senior Partner, Technology, Media & Entertainment Sector Lead

How have obligations under the Digital Markets Act (DMA) been enforced recently and what are the ramifications for a lack of compliance?

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Thinking - Snapshot

EU Commission's call for evidence on European Business Wallet

Published on 23 Sep 2025. By Oliver Bray, Senior Partner, Technology, Media & Entertainment Sector Lead

What is the new European Business Wallet and how could businesses benefit from it?

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Thinking - Snapshot

EU Commission seeks feedback on guidelines for the protection of minors online under the Digital Services Act

Published on 23 Sep 2025. By Oliver Bray, Senior Partner, Technology, Media & Entertainment Sector Lead

What might the change in the Digital Services Act (DSA) guidelines mean for providers of online platforms that can be used by minors?

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Thinking - Publication

Generative AI – addressing copyright

Published on 22 Sep 2025. By Ciara Cullen, Partner, Consumer Brands & Retail Sector Lead and Joshy Thomas, Senior Knowledge Lawyer and Rory Graham, Associate

When it comes to the interaction of AI and IP rights, most attention and litigation has been focussed on copyright. The three main issues are whether: (1) the way FMs are trained using works from the internet infringes the copyright in the works of content creators such as authors, artists and software developers; (2) the outputs of FMs infringe the copyright of content creators; and (3) AI generated works are protectable.

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Thinking - Publication

Cyber_Bytes - Issue 75

Published on 04 Aug 2025. By Richard Breavington, Partner and Daniel Guilfoyle, Partner and Rachel Ford, Partner and Ian Dinning, Senior Associate and Christopher Ashton, Senior Associate and Elizabeth Zang, Associate and Emanuele Santella , Associate and Lauren Kerr, Associate

Welcome to Issue 75 of our Cyber_Bytes, our regular round-up of key developments in cyber, tech and evolving risks.

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Thinking - Blog

EU-UK data adequacy renewal - proceed with caution

Published on 28 Jul 2025. By Cavan Fabris, Partner, Head of Data & Cyber and Sophie Hudson, Associate

The EU-UK draft adequacy renewal was published last week. Partner Cavan Fabris and trainee Sophie Hudson from our Cyber & Data Privacy team have summarised the key takeaways below.

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Thinking - Publication

Data Dispatch - June 2025

Published on 27 Jun 2025. By Jon Bartley, Partner and Helen Yost, Senior Associate and Amy Blackburn, Senior Associate and Praveeta Thayalan, Senior Knowledge Lawyer and Kiran Dhoot, Associate

Welcome to our June 2025 edition of Data Dispatch from the Data Advisory team at RPC. Our aim is to provide you on a regular basis with an easy-to-digest summary of key developments in data protection law.

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Thinking - Publication

What is a foundation model?

Published on 11 Jun 2025. By Caroline Tuck, Partner and Joshy Thomas, Senior Knowledge Lawyer and Rory Graham, Associate

Foundation Models (FM), also often known as general purpose AI, are a type of AI technology that are trained on large datasets and are capable of carrying out a wide range of "general" tasks and operations.

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Thinking - Publication

Part 1 - UK AI regulation

Published on 11 Jun 2025. By Caroline Tuck, Partner and Praveeta Thayalan, Senior Knowledge Lawyer and Ricky Cella, Senior Associate

There has been consistent messaging from the UK Conservative-led government that the UK has decided to adopt a light touch approach to regulating AI. This was evident in the AI white paper published in March 2023 which outlined a principles based framework (see ['The Ethics of AI – the Digital Dilemma'] for more information about the principles themselves and see here for additional coverage of the AI white paper). The UK government held a consultation on the AI white paper in 2023 and published a response on 6 February 2024 that adds slightly more flesh to the bones of the UK framework.

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Thinking - Publication

The Role of AI in Disputes

Published on 10 Jun 2025. By Daniel Hemming, Partner and Ricky Cella, Senior Associate and Joshy Thomas, Senior Knowledge Lawyer

While lawyers have had various forms of AI available to them for years, it is generative AI and the development of large language models (LLMs) which is likely to represent a fundamental shift for dispute resolution. This technology now offers language capabilities that have never been seen before, and is likely to transform the way lawyers conduct proceedings.

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Thinking - Publication

AI and Privacy – 10 Questions to Ask

Published on 10 Jun 2025. By Jon Bartley, Partner and Praveeta Thayalan, Senior Knowledge Lawyer

We set out in this section 10 key questions to ask yourself at the outset when developing or deploying AI solutions in your business.

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Thinking - Publication

The Ethics of AI - The Digital Dilemma

Published on 10 Jun 2025.

This is Part 6 of 'Regulation of AI – raising the trillion dollar bAIby'

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Thinking - Publication

Part 6 – Practical Considerations

Published on 10 Jun 2025. By Caroline Tuck, Partner and Ricky Cella, Senior Associate and Praveeta Thayalan, Senior Knowledge Lawyer

AI focussed actors and providers have been focussing on their forthcoming AI obligations and on governance for some time, but it is now prudent for the majority of organisations to assess how their use of AI will come within the scope of regulation in key territories and become familiar with each regime (and devise a means to keep up with the anticipated fast moving changes). Planning for the costs of compliance and for AI governance including systems and procedures for data retention and record keeping should also be part of current business strategy together with building expertise on AI internally and identifying trusted advisors from the "noise" of what is being offered externally.

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