The United Kingdom Ministry of Justice is engaged in a consultation on the impact of the proposal of the European Commission for a Data Protection Regulation to replace the EU Directive and implementing legislation, and solicited submissions by 6 March. On 29 February 2012, Hogan Lovells held a session in London for clients where we sought and obtained views on the impact of the proposals made by the European Commission for a new Data Protection Regulation. Yesterday, the firm made a submission to the Ministry of Justice on the proposed Regulation. This document contains a distillation of our own observations and comments made to us by clients since the proposals first became public knowledge.
A copy of the submission is available here.
In the submission, we address many aspects of the proposal of the European Commission, including the costs of compliance, impact assessments, the "right to be forgotten," data portability, international transfers, data breaches, jurisdiction and penalties.
This project was initiated and organized by London data protection partner Quentin Archer, with contributions by London partner Roger Tym, Paris partner Winston Maxwell and other lawyers in the firm’s privacy practice.