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Internal Monitoring - The Legislator reverts to the issue of antitrust compliance

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Case comment: Amey Highways Limited v West Sussex County Council

The recent High Court decision in Amey Highways Limited v West Sussex County Council has clarified that abandoning a procurement will not automatically extinguish pre-existing causes of action.  Breaches of the procurement regulations which res...


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UK Government loses case relating to Saudi Arabia arms exports

On 20 June 2019, the UK Court of Appeal ruled that the UK Government’s decision to continue licensing exports of military equipment to Saudi Arabia for possible use in the conflict in Yemen was unlawful. The judgment comes amidst global concer...


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CMA's merger enforcement powers could become more intrusive

On 3 June 2019, the Competition and Markets Authority (“CMA”) published a report1 by economic consultancy firm Lear, commissioned by the CMA, on merger control in digital markets (“Report”). On the...


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Narrow or Wide? Court aligns Germany with other jurisdictions on MFN-Clauses in Bookings.com case

On 4 June 2019 the Higher Regional Court of Düsseldorf ruled in favour of Booking.com’s revised “narrow” Most Favourite Nation (“MFN”) clause (Case No. VI-Kart 2/16 (V)). The reactions were predictable. German hote...


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US lifts the Cuba secondary sanctions waiver

The United States (“US”) Government announced on 17 April 2019 that it would not renew a waiver to Title III of the US Helms-Burton Act 1996 (“Title III”) that had effectively prevented former owners of property confiscated f...


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Greater EU Competition Enforcement needed in the Digital Era

As we have recently reported, a number of competition authorities and governments are in the process of assessing whether their competition enforcement tools are fit for the digital economy. In the UK, on 13 March 2019 a specially commissioned panel...


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First fine imposed for obstructing CMA inspection

On 20 March 2019 the Competition and Markets Authority (‘CMA’)  imposed a fine  of £25,000  on the guitar supplier Fender Musical Instruments Europe Limited (‘Fender Europe’) for failure to comply with a ...


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UK Competition law – Is it fit for the digital economy?

With the rapid growth of the digital economy, a number of competition authorities, as well as governments1 are in the process of assessing whether their competition enforcement tools are fit for the digital economy. In the UK, the Government commiss...


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UK competition regime set to become stricter and more burdensome for businesses post-Brexit

The UK’s departure from the EU is set to lead to a significant change to the UK’s overall approach to competition law. Currently, the UK is required to retain close alignment with EU competition law, which includes respecting the Europea...


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Case C-260/17, Anodiki Services EPE: interpreting the scope of the “employment contracts” exemption under EU procurement legislation

Case C-260/17, Anodiki Services EPE1: interpreting the scope of the “employment contracts” exemption under EU procurement legislation Introduction The judgment relates to a request for a preliminary ruling made by Greece’s Council ...


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Sainsbury's / Asda and the CMA - a statement of intent pre-Brexit

On 21 and 20 February 2019 respectively the Competition and Markets Authority (CMA) published its Provisional Findings and a View Details..

FCA imposes fines in first competition enforcement case

Competition partner Julia Woodward-Carlton, who acted for one of the main parties on this case, considers the decision and potential implications of the case in this article. The Financial Conduct Authority (‘FCA’) has today issued ...


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CAT rejects Electro Rent appeal against procedural fine

The Competition Appeal Tribunal (CAT) has dismissed an appeal by Electro Rent against a fine of £100,000 imposed for failing to comply with the terms of an interim order (the “order”). Interim orders are a key tool employed by the ...


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The General Court annuls the Commission’s 2016 decision on the Belgian excess profit tax rulings

The General Court of the European Union annulled on 14 February the European Commission’s decision of 11 January 2016 (Decision (EU) 2016/1699), in which it had found that Belgium’s excess profit exemption scheme was incompatible with EU...


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The EU Court provides guidance on the use of framework agreements by contracting authorities

Case C-216/17, Autorità Garante della Concorrenza e del Mercato – Antiturst, Coopservice Soc. coop. arl In its judgment of 19 December 2018 (the &ldq...


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Coronavirus - Returning to the office: back to normal? - UK

This week, the Government intends to set out its “road map” to “unlock the economy” and get people back to work. Therefore, in the not too distant future (hopefully sooner rather than later for the majority), businesses will ...


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Coronavirus - Protecting your company and brand - Global

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When does private no longer mean private? Implications of a challenge to the SFC’s accessing of digital devices in an investigation

The Hong Kong Court has recently confirmed the Securities and Futures Commission (“SFC”)’s powers to seize, search and compel access to digital devices rejecting challenges to such powers based on privacy grounds. Data privacy is a...


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Coronavirus – Data Protection considerations for alternative communication platforms – Global

How does the communication within a team take place in the home office? Due to the increasing intensity of preventive measures against the spread of corona, more and more companies are closing down their locations and, where possible, relocating bus...


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Coronavirus - The use of Personal Data in connection with Covid-19 – Hong Kong

As a general rule of data privacy protection in Hong Kong, personal data should be used only for the original purpose for which the data was collected, or a directly related purpose. One exception is where the data user obtains the consent from the ...


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Further Judicial Recognition of Bitcoin as “Property” Following Ransomware Attack

The Court in AA v Persons Unknown [2019] EWHC 3556 (Comm) (17 January 2020) ordered injunctive relief against unknown persons accused of extorting ransom payments in the form of Bitcoin worth $950,000 from an insurance company, following a cyber-att...


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Commencement of the Protection of Personal Information Act – 1 April 2020

President Cyril Ramaphosa has received a request from the Information Regulator Chairperson to declare that the remaining provisions of the Protection of Personal Information Act (POPIA) commence on 1 April 2020. If the President acts on the Informa...


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New regulations permit the Central Bank of Ireland to limit the rights of data subjects under the GDPR

Precis: In this briefing, we look at the new regulations permitting the Central Bank of Ireland to limit the rights of individuals under the GDPR. On 30 October 2019 the Data Protection Act 2018 (section 60(6)) (Central Bank of Ireland) Regulations ...


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Update: Advocate General advises that the validity of standard contractual clauses is not affected by complaints made in Schrems II

What do I need to know? On Thursday 19 December, Advocate General Saugmandsgaard Øe published his Opinion in View Details..

Speed read: Useful November 2019 guidelines on controller, processor and joint controllership concepts from the European Data Protection Supervisor

Summary On 7 November 2019 the EDPS issued guidance on how to determine who is a controller, processor and joint controller. The EDPS is an independent supervisory authority whose primary objective is to ensure EU institutions and bodies respect the...


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Disinformation and the digital wild west

The digital modern age offers huge potential – the sharing of new technologies, the promotion of economic growth and the ability for instant communication. But whilst products of this age, such as social media, may help to progress today&rsqu...


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ICO launches consultation on its application for POCA enforcement powers

The Information Commissioner’s Office (“ICO”) has asked to be given the ability to exercise various powers (and gain access to investigation) under the Proceeds of Crime Act 2002 (“POCA”), and has opened a consultation ...


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A review of the Online Harms White Paper

In response to the surge of harmful and illegal content being spread online, the Government currently deliberates legislation for 2020 to establish a regulatory framework that will attempt to make the UK “the safest place in the world to be on...


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ICO in action: Ban on unsolicited marketing calls to members of pension schemes

This speed read follows on from our briefing in November 2018 in which we explained that the government had proposed a change in law to implement a ban specific to pensions related cold calling.  At that time it was estimated that 10.9 million ...


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Floodgates open on class actions in data protection

Court of appeal overturns High Court judgment in Lloyd v Google LLC [2019] EWCA Civ 1599 Court of Appeal judgment The Court of Appeal has given the go-ahead for a representative claim to be served on Google LLC in the U.S. for alleged data breaches,...


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German data protection authorities agree on calculation model for GDPR fines

While fines recently imposed by the French and UK data protection supervisory authorities have been high, the supervisory authorities in Germany have so far imposed rather moderate penalties. This could now be changed by a new model for calculating ...


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Decision of the Higher Regional Court of Frankfurt am Main on bundling of consents in sweepstakes

In its decision of 27. June 2019 (Ref. 6 U 6/19), the Higher Regional Court of Frankfurt am Main ruled that participation in a sweepstakes can be made dependent on participants giving their consent to receive future marketing via e-mail or calls. In...


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Article: Pre-ticked boxes aren’t “consent” for cookie placement

CJEU Ruling on Cookies On 1 October 2019, the Court of Justice of the European Union (CJEU) gave a preliminary ruling1  on questions referred from the Bundesgerichtshof (Federal Court of Justice in Germany) that:   Consent is not validly ...


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Bank Negara Malaysia - Policy Guidance on ‘Risk Management in Technology’ (‘RMiT’)

The Central Bank of Malaysia or Bank Negara Malaysia (‘BNM’) on 18 July 2019 issued another policy document which sets out its requirements to the nation’s Financial Institutions (‘FIs’) management of technology risk. W...


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A transparent process: Irish DPC issues new guidance on data sharing in the public sector

The Data Protection Commission (“DPC”) issued guidance on data sharing in the public sector. The DPC noted its support for developing more efficient and customer-centric public services and sought to clarify the public sector obligations...


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ICO updates guidance on ‘manifestly unfounded’ and ‘excessive’ in the context of responding to individuals’ rights

What you need to know UK regulatory guidance has been updated to explain what ‘manifestly unfounded’ and ‘excessive’ means in relation to the individual rights of data subjects under GDPR. This includes but is not limited to ...


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Have you read the draft EDPB guidelines for the use of video devices (eg CCTV)? Perhaps you should – if you use such video devices

Quick Read Many readers may have chosen to skip looking at the Guidelines that the EDPB published for consultation recently, if you are one of them, and you routinely use CCTV (or other similar devices) within your business – you may want to h...


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ICO updates guidance on timescales for responding to individuals’ rights: Date of receipt is ‘day one’

What you need to know UK regulatory guidance has been updated to the effect that the timescale for responding to individuals’ requests (including subject access requests) is one calendar month from the day of receipt of the ...


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The Fashion ID judgement: Plugin to be a joint controller

The Facebook “Like” button and similar social media plugin technologies (Plugin) are now so commonplace that we perhaps don’t give them a second thought. Plugins provide an easy way for consumers to connect instantly with a preferr...


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Operational Resiliency for Financial Institutions

The operational resilience of retail banks operating in the United Kingdom has come under increased scrutiny following a number of high-profile IT failures and cyber-attacks. Regulators have shown a willingness to impose significant penalties for IT...


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ICO issues the long awaited data sharing code of practice for consultation

The ICO has launched a public consultation on its new draft data sharing code of practice. The consultation period ends on 9 September 2019. It is an update of the previous code, to align it with GDPR so as to address transparency, lawful bases for ...


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Irish Data Protection Commissioner (DPC) issues guidance on CCTV for controllers

The DPC has published useful guidance on CCTV usage for controllers. The guidance is intended to assist owners and occupiers of premises to understand their responsibilities and obligations regarding data protection when using CCTV. This is particul...


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Stepping into the breach - Managing cyber risks with insurance

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UK adopts new EU-driven restrictive measures to deter and respond to external cyber-attacks through financial sanctions

On 17 May 2019, the European Council established a framework and implemented a new sanctions regime which now allows the EU to impose targeted sanctions to “deter and respond to cyber-attacks which constitute an external threat to the EU and i...


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Six reasons to care about Brazil’s new data protection law

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GDPR one year on…

The passage of a year since GDPR came into force has been a marker for the ICO and others to pause, reflect, and (importantly) for the ICO to give some indications as to what lies ahead. The ICO has published a blog post. It is a useful snapshot of ...


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The new Swedish Protective Security Act

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Taking stock - what has and hasn’t been working since the GDPR’s introduction last May

Lorna Doggett examines what has and hasn’t been working since the GDPR’s introduction last May. To read the full article click here > This article was published in the April 2019 edition of Intellectual Property Magazine, and is repro...


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Consultation on proposals to regulate consumer IoT device security

On 1 May 2019 the UK government, through the Department for Digital, Culture, Media & Sport, launched a consultation on its proposals to regulate the security of consumer Internet of Things (“IoT”) or “smart” devices, whi...


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