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CMA updates AI Foundation Model principles amid concerns about how the sector is developing Last week, the CMA published an update to its initial report on AI Foundation Models published last September.  The initial report has been widely praised, with stakeholders and practitioners commending the CMA for its work to understand these complex...
New ICO fining guidance and an update on the ICO's enforcement approach The sheer number of cases facing potential enforcement coupled with the shifting versions of draft guidance have, in recent years, made it hard to predict what (if any) action the ICO would take and when (if at all) an investigation might be concluded....
Cyber update – what’s been happening in Q1 2024 As Q1 2024 comes to a close, I look back at some of the key cyber developments that have been keeping us, and our clients, busy so far this year: UK organisations more likely to pay ransoms:  We are continuing to advise clients on ransomware attacks, and...
Who’s who? ICO clarifies rules for biometric recognition Facial recognition has been in the headlines over the last year, both in usage by police and more widely, such as shops identifying known shoplifters and by employers monitoring employees. Most recently its been in the news because the ICO has required...
Recent developments in respect of the Italian investment management exemption regime Does an Italian investment manager create a permanent establishment for a foreign investment vehicle? Not necessarily – especially now that the investment management exemption (IME) has been implemented. The IME is an important safe harbour for the...
Amazon in the firing line as UK Supreme Court tackles targeting The UK Supreme Court has confirmed that Amazon infringed Lifestyle Equities’ UK and EU trade marks by offering for sale certain third party goods to UK consumers through its US website, Amazon.com. This is the first time that the Supreme Court has...
Data scraping: ICO’s first attempt at legal clarity Data scraping or “web scraping” has various definitions but essentially means the process of gathering, copying or extracting information (including text, images and videos and therefore often personal data) from the internet with a view to storing that...
Are you ready for the EU AI Act? Final vote in the European Parliament passed today The EU AI Act has passed one of its final hurdles before becoming law. While provisional political agreement on the Act was reached before Christmas (see our blog), further work was required to iron out some of the ‘technical’ details, and it still needed...
ICO Consultation Series on Gen AI: Second Call The ICO has launched its second call for evidence as part of its consultation series on data privacy and generative AI. The ICO’s first call for evidence covered the lawful basis for training generative AI models on web-scraped data (see our earlier blog)...
“Pay or consent” models – a way forward? This week the ICO launched a call for views on the use of “pay or consent” models in the context of ad-funded online business models, many of which rely on cookies or similar tracking technologies.  Data privacy concerns around “pay or consent” models  A...