Gabriela Zanfir-Fortuna
@gzf.bsky.social
Data Protection Geek. Co-author of the big GDPR OUP Commentary🇷🇴🇪🇺🇺🇸 US-based, former Brussels bubbler. Writes about data protection law and policy, AI governance through a Global lens (& sometimes democracy) Strictly personal views.
www.pdpecho.com.
www.pdpecho.com.
Hold your horses 🐴 The CJEU itself clarifies that having to comply as an online platform with the #GDPR to prevent unlawful processing of sensitive data *is not* an obligation of general monitoring.
It’s right there in the judgment, spelled out, at para 132.
#Russmedia
It’s right there in the judgment, spelled out, at para 132.
#Russmedia
December 5, 2025 at 9:17 PM
Hold your horses 🐴 The CJEU itself clarifies that having to comply as an online platform with the #GDPR to prevent unlawful processing of sensitive data *is not* an obligation of general monitoring.
It’s right there in the judgment, spelled out, at para 132.
#Russmedia
It’s right there in the judgment, spelled out, at para 132.
#Russmedia
#Russmedia is the gift that keeps on giving. First time the Court states this re: accuracy:
"every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay."
CC: AI developers 👀
"every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay."
CC: AI developers 👀
December 5, 2025 at 6:07 PM
#Russmedia is the gift that keeps on giving. First time the Court states this re: accuracy:
"every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay."
CC: AI developers 👀
"every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay."
CC: AI developers 👀
I’ll take it 😇 🤪
December 4, 2025 at 1:33 AM
I’ll take it 😇 🤪
😱 I cannot order Rituals anymore in the US because of the tariffs, what a travesty 😱
November 29, 2025 at 3:41 AM
😱 I cannot order Rituals anymore in the US because of the tariffs, what a travesty 😱
Today was a good day at the office, by far one of my favorite FPF LinkedIn Lives I've had. My guest: Philippe Dufresne, Federal Privacy Commissioner of Canada 🇨🇦, whose office was recently appointed as the Chair of the Global Privacy Assembly!
🎥 www.linkedin.com/events/globa...
What we've learned 1/
🎥 www.linkedin.com/events/globa...
What we've learned 1/
November 26, 2025 at 7:32 PM
Today was a good day at the office, by far one of my favorite FPF LinkedIn Lives I've had. My guest: Philippe Dufresne, Federal Privacy Commissioner of Canada 🇨🇦, whose office was recently appointed as the Chair of the Global Privacy Assembly!
🎥 www.linkedin.com/events/globa...
What we've learned 1/
🎥 www.linkedin.com/events/globa...
What we've learned 1/
Finally, the definition of an “AI system” under the AI Act will matter 😅 Because, remember, the vast majority of AI systems are not covered by any obligations of the AI Act, as COM guidance also makes obvious. But sensitive data could be used for any AI systems, per the #GDPROmnibus
November 19, 2025 at 9:30 PM
Finally, the definition of an “AI system” under the AI Act will matter 😅 Because, remember, the vast majority of AI systems are not covered by any obligations of the AI Act, as COM guidance also makes obvious. But sensitive data could be used for any AI systems, per the #GDPROmnibus
I asked Gemini's image editing mode to transform my headshot in Magritte style. I had a bit of Brussels blues today. Nailed it 🤣
Soon, at a conference close to you 🍏🎩
Soon, at a conference close to you 🍏🎩
August 29, 2025 at 9:20 PM
I asked Gemini's image editing mode to transform my headshot in Magritte style. I had a bit of Brussels blues today. Nailed it 🤣
Soon, at a conference close to you 🍏🎩
Soon, at a conference close to you 🍏🎩
In DC today for the #DCPrivacyForum, bringing to DC some views from around the world from the law of data protection as AI regulation 🤓 Things are moving and shifting in this space: Have you checked recent movements in South Korea and the EU?
June 11, 2025 at 2:53 PM
In DC today for the #DCPrivacyForum, bringing to DC some views from around the world from the law of data protection as AI regulation 🤓 Things are moving and shifting in this space: Have you checked recent movements in South Korea and the EU?
Thank you to all the panelists for sharing their knowledge with the audience, to #CPDP25 for hosting this conversation, and especially to our attendees who filled the room to the point where some had to stand to be there. 9/9
May 23, 2025 at 12:38 PM
Thank you to all the panelists for sharing their knowledge with the audience, to #CPDP25 for hosting this conversation, and especially to our attendees who filled the room to the point where some had to stand to be there. 9/9
"Flooding the zone" - now that we have a word for it, this is how it felt the European Commission did with the legislative proposals of the Data Strategy package in the past 4-5 years. With one of the results being … 1/
May 23, 2025 at 12:15 PM
"Flooding the zone" - now that we have a word for it, this is how it felt the European Commission did with the legislative proposals of the Data Strategy package in the past 4-5 years. With one of the results being … 1/
What an honor to hear Mireille Hildebrandt live, keynoting, during the Opening Night at #CPDP25
She recalls on how back in 2009 at the same conference together w A. Rouvroy they organized a philosophers’ seminar on IBM’s concept of “autonomic computing”.
She recalls on how back in 2009 at the same conference together w A. Rouvroy they organized a philosophers’ seminar on IBM’s concept of “autonomic computing”.
May 20, 2025 at 4:49 PM
What an honor to hear Mireille Hildebrandt live, keynoting, during the Opening Night at #CPDP25
She recalls on how back in 2009 at the same conference together w A. Rouvroy they organized a philosophers’ seminar on IBM’s concept of “autonomic computing”.
She recalls on how back in 2009 at the same conference together w A. Rouvroy they organized a philosophers’ seminar on IBM’s concept of “autonomic computing”.
Miriam Wimmer (Brazilian ANPD, the Data Protection Authority) is giving a masterclass at the Joel Reidenberg lecture (@Fordham Law) on data protection law and its global vocation as applied to emerging technologies, starting from 2 concrete cases re: training LLMs & buying iris scans w crypto.
April 29, 2025 at 8:22 PM
Miriam Wimmer (Brazilian ANPD, the Data Protection Authority) is giving a masterclass at the Joel Reidenberg lecture (@Fordham Law) on data protection law and its global vocation as applied to emerging technologies, starting from 2 concrete cases re: training LLMs & buying iris scans w crypto.
Next week I’ll be in DC for IAPP Summit #GPS25, moderating a panel about crossregulatory cooperation (otherwise known as making sense of all the digital laws, everywhere, all the time, coherently). With Brando Benifei, MEP of the AI Act fame, John Edwards (ICO) & Louisa Specht (Federal German DPA)
April 17, 2025 at 3:10 PM
Next week I’ll be in DC for IAPP Summit #GPS25, moderating a panel about crossregulatory cooperation (otherwise known as making sense of all the digital laws, everywhere, all the time, coherently). With Brando Benifei, MEP of the AI Act fame, John Edwards (ICO) & Louisa Specht (Federal German DPA)
A 💙 from Bucharest tonight, for Europe and against Kremlin grab of Eastern Europe.
March 15, 2025 at 8:52 PM
A 💙 from Bucharest tonight, for Europe and against Kremlin grab of Eastern Europe.
... The possibility of propagating a records-oriented citizenry that has lost its autonomy and individuality must be avoided." end of this paragraph. The experts proposing safeguards as FIPPS back then were smart, and had foresight, I think. At least, it's worth studying their work. 5/5
February 6, 2025 at 6:07 PM
... The possibility of propagating a records-oriented citizenry that has lost its autonomy and individuality must be avoided." end of this paragraph. The experts proposing safeguards as FIPPS back then were smart, and had foresight, I think. At least, it's worth studying their work. 5/5
👀 I was not expecting DeepSeek to be the word of the day in Brussels at CPDP #DataProtectionDay #DPD25
Wojciech Wiewiorowski named it the “Sputnik Moment” in AI…
Wojciech Wiewiorowski named it the “Sputnik Moment” in AI…
January 28, 2025 at 10:14 AM
👀 I was not expecting DeepSeek to be the word of the day in Brussels at CPDP #DataProtectionDay #DPD25
Wojciech Wiewiorowski named it the “Sputnik Moment” in AI…
Wojciech Wiewiorowski named it the “Sputnik Moment” in AI…
January 26, 2025 at 9:40 AM
The American surge on Little Red Book/RedNote app might be short lived after all 👀 You see, the app is entirely subject to PRC censorship rules and an influx of American content might disturb a bit the waters. From The Economist:
www.economist.com/united-state...
www.economist.com/united-state...
January 18, 2025 at 6:34 PM
The American surge on Little Red Book/RedNote app might be short lived after all 👀 You see, the app is entirely subject to PRC censorship rules and an influx of American content might disturb a bit the waters. From The Economist:
www.economist.com/united-state...
www.economist.com/united-state...
Europe in this story? 4/4
January 18, 2025 at 4:51 PM
Europe in this story? 4/4
I also found it interesting that SCOTUS relied throughout its sefuments on a kind of “necessity & proportionality” test, as we call it in EU law, finding that the provisions in the assessed law are not “substantially broader than necessary” to achieve its goals. 8/
January 17, 2025 at 11:41 PM
I also found it interesting that SCOTUS relied throughout its sefuments on a kind of “necessity & proportionality” test, as we call it in EU law, finding that the provisions in the assessed law are not “substantially broader than necessary” to achieve its goals. 8/
One fascinating parallel I found was also the fact that for both the US Supreme Court and for the CJEU it wasn’t material whether the foreign government *actually* accessed the personal data, or the access likelihood, but that it has the *possibility* to do so, based on the foreign law. 7/
January 17, 2025 at 11:02 PM
One fascinating parallel I found was also the fact that for both the US Supreme Court and for the CJEU it wasn’t material whether the foreign government *actually* accessed the personal data, or the access likelihood, but that it has the *possibility* to do so, based on the foreign law. 7/
“That rationale is decidedly content agnostic”, the Court says, + “the data collection justification reflects a purpose unrelated to the content of expression”. This finding might be very interesting in the US debate on how legislative limits for collection of personal data “infringe free speech” 3/
January 17, 2025 at 10:39 PM
“That rationale is decidedly content agnostic”, the Court says, + “the data collection justification reflects a purpose unrelated to the content of expression”. This finding might be very interesting in the US debate on how legislative limits for collection of personal data “infringe free speech” 3/
My heart and soul are in Piata Universitatii in #Bucharest right now ❤️ #Romania
Some thousands of people are out in the streets at a pro-EU, pro-democracy rally, amidst Russia’s influence campaign to have its mystic puppet elected for President this weekend.
Live Updates: hotnews.ro/protest-in-p...
Some thousands of people are out in the streets at a pro-EU, pro-democracy rally, amidst Russia’s influence campaign to have its mystic puppet elected for President this weekend.
Live Updates: hotnews.ro/protest-in-p...
December 5, 2024 at 7:19 PM
My heart and soul are in Piata Universitatii in #Bucharest right now ❤️ #Romania
Some thousands of people are out in the streets at a pro-EU, pro-democracy rally, amidst Russia’s influence campaign to have its mystic puppet elected for President this weekend.
Live Updates: hotnews.ro/protest-in-p...
Some thousands of people are out in the streets at a pro-EU, pro-democracy rally, amidst Russia’s influence campaign to have its mystic puppet elected for President this weekend.
Live Updates: hotnews.ro/protest-in-p...
Here’s a Birdseye view of it! Oh boy!
December 5, 2024 at 5:14 PM
Here’s a Birdseye view of it! Oh boy!