On 2 July 2018, the French Data Protection Authority (“Commission Nationale de l’Informatique et des Libertés” or “CNIL”) published its yearly thematic guidance for the priority axes of its control activities, notably further to the entry into force of the recent General Data Protection Regulation (“GDPR”).

As for the previous periods, the CNIL is expecting to launch 300 dawn-raids, either on premises or online, in order to control compliance of companies subject to French and European data protection regulations, notably on newly introduced aspects relating to the implementation of GDPR (right to portability, data protection impact assessments…).

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K&L Gates ranked “Excellent” with E. Drouard & Claude-Etienne Armingaud.

Source: Leaders League

K&L Gates ranked “Highly Recommended – Band 1” with E. Drouard & Claude-Etienne Armingaud.

Source: Leaders League

K&L Gates ranked “Recommended – Band 2” with E. Drouard & Claude-Etienne Armingaud.

Source: Leaders League

K&L Gates LLP’s E. Drouard has substantial experience in advising clients on data protection while Claude-Etienne Armingaud specialises in cross-border transactions and outsourcing contracts in the fields of fintech, IoT and big data.

Notable transactional work included Armingaud’s advice to Bridgestone on its €12m share deal with Eliocity/Xee, which also entailed assistance with IT, IP and data protection due diligence. On the data protection front, the practice’s caseload includes advice to Carglass on the implementation of its GDPR compliance programme, and assisting BNP Paribas with its personal data privacy policy. The department’s client roster also includes JCDecaux, Microsoft, SNCF and SloClap.

Source: Legal 500

The French Autorité des Marchés Financiers has recently published a synthesis of the contributions it received in response to its public consultation on Initial Coin Offerings (ICOs) to obtain stakeholder views on how these new types of blockchain offerings might be regulated.

The consultation included a presentation of ICOs, a warning on the risks they present, a legal analysis of ICOs with respect to the rules overseen by the AMF and the regulatory options proposed by the AMF. Respondents were invited to give their views on all of these points.

The English version of the synthesis can be found here, the French version here and our previous coverage of the consultation can be found here.

First published on K&L Gates Fintech Law Blog.

Mode information on K&L Gates website

On 26 October 2017, France’s Financial Markets Authority, the “Autorité des Marchés Financiers” (“AMF”), published a discussion paper focusing on initial coin offerings (“ICOs”) that highlights the (many) dangers that arise from these unregulated transactions and discusses the regulation options that it currently foresees.
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On 17 October 2017, after about 18 months of waiting, a consultation involving more than 20 players, and two intermediate versions, the French Data Protection Authority (“Commission Nationale de l’Informatique et des Libertés” or “CNIL”) has released the final version of its “compliance package” on Connected Cars (“Compliance Package”).

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In June 2017, the Article 29 Working Party – the gathering the all Member States’ Data Protection Authorities (DPAs) – announced that the five last guidelines to be adopted as companion pieces to the General Data Protection Regulation (“GDPR”) would be published in December 2017. Further to this announcement, the French DPA, the CNIL, is now seeking the contributions of the relevant stakeholders impacted by two out of five topics, whether they be sole or joint “data controllers”, “data processors” or “data subjects”.

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