When people agonise about being ‘ready’ for #GDPR, think about this: How can anyone be ready when we are all still debating which lawful grounds for processing (consent/contractual necessity/legitimate interests) apply to some of the most common uses of data? 1/4
Aside from obvious cases, determining the lawful ground for processing is a critical aspect of #EUdataP which is extremely difficult to get right, because it rests on the correct legal interpretation of complex concepts like ‘consent’, ‘necessity’ & ‘rights and freedoms’ 2/4
But since under #GDPR you have to reveal which lawful ground you rely on, everyone is taking a view which may or may not be right in the end. We simply don’t know with 100% certainty and it will take years of enforcement and court decisions to know for sure. 3/4
And that’s just one basic element of the #GDPR which has existed in the law for 20 yrs. So my advice & plea is that we stop thinking of 25 May as a ‘deadline’ and we look at #EUdataP as a framework we need to constantly observe as part of our involvement in the digital world. 4/4
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