Markus Sullivan
@mjsullivan.bsky.social
In-House Lawyer on International Data & Tech, Law and Policy
Reposted by Markus Sullivan
Netherlands raises serious concerns about EU Digital Omnibus privacy changes #DigitalPrivacy #GDPR #DataProtection #EURegulation #PrivacyConcerns
Netherlands raises serious concerns about EU Digital Omnibus privacy changes
Dutch government warns proposed GDPR amendments could substantially weaken data protection without effectively reducing regulatory burden for businesses.
ppc.land
December 13, 2025 at 10:36 AM
Netherlands raises serious concerns about EU Digital Omnibus privacy changes #DigitalPrivacy #GDPR #DataProtection #EURegulation #PrivacyConcerns
Reposted by Markus Sullivan
The German DPAs have issued their position on proposed GDPR reform, expressing reservations about the modification to the definition of personal data. They emphasize that such change could affect the fundamental right to data protection as well as alter the scope of the GDPR.
December 12, 2025 at 4:46 PM
The German DPAs have issued their position on proposed GDPR reform, expressing reservations about the modification to the definition of personal data. They emphasize that such change could affect the fundamental right to data protection as well as alter the scope of the GDPR.
December 12, 2025 at 4:39 PM
Reposted by Markus Sullivan
The GDPR set the global standard for privacy legislation. Now the European Commission wants to gut GDPR privacy protections with its "Digital Omnibus" proposal. Don't be fooled—this threatens everyone's privacy rights. www.eff.org/deeplinks/2...
EU's New Digital Package Proposal Promises Red Tape Cuts but Guts
The European Commission (EC) is considering a “Digital Omnibus” package that would substantially rewrite EU privacy law, particularly the landmark General Data Protection Regulation (GDPR). It’s not
www.eff.org
December 10, 2025 at 2:03 AM
The GDPR set the global standard for privacy legislation. Now the European Commission wants to gut GDPR privacy protections with its "Digital Omnibus" proposal. Don't be fooled—this threatens everyone's privacy rights. www.eff.org/deeplinks/2...
If you wondered, I guess the Commissions answer was call, not fold.
The European Commission has opened a formal antitrust investigation to assess whether Google has breached EU competition rules by using the content of web publishers, as well as content uploaded on the online video-sharing platform YouTube for AI purposes
ec.europa.eu/commission/p...
ec.europa.eu/commission/p...
Commission opens investigation into possible anticompetitive conduct by Google in the use of online content for AI purposes
The European Commission has opened a formal antitrust investigation to assess whether Google has breached EU competition rules by using the content of web publishers, as well as content uploaded on th
ec.europa.eu
December 9, 2025 at 10:48 AM
If you wondered, I guess the Commissions answer was call, not fold.
💚 Help shape IAPP #KnowledgeNet Munich 2026!
🌈 This year we tried to be more inclusive, involve younger pros & add privacy engineering, while keeping what works and testing new formats
🛠️ Did you feel it? What should change? Take the survey by 19 Dec 2025.
iappwf.questionpro.com/a/TakeSurvey...
🌈 This year we tried to be more inclusive, involve younger pros & add privacy engineering, while keeping what works and testing new formats
🛠️ Did you feel it? What should change? Take the survey by 19 Dec 2025.
iappwf.questionpro.com/a/TakeSurvey...
IAPP Munich KnowledgeNet Chapter Survey to Collect Ideas
iappwf.questionpro.com
December 8, 2025 at 5:47 PM
💚 Help shape IAPP #KnowledgeNet Munich 2026!
🌈 This year we tried to be more inclusive, involve younger pros & add privacy engineering, while keeping what works and testing new formats
🛠️ Did you feel it? What should change? Take the survey by 19 Dec 2025.
iappwf.questionpro.com/a/TakeSurvey...
🌈 This year we tried to be more inclusive, involve younger pros & add privacy engineering, while keeping what works and testing new formats
🛠️ Did you feel it? What should change? Take the survey by 19 Dec 2025.
iappwf.questionpro.com/a/TakeSurvey...
Reposted by Markus Sullivan
📝 #DigitalOmnibus - First Feedback 💭 Are you a DPO, lawyer or other #privacy professional? We would like to know your first impressions of the proposed changes to the #GDPR. 🇪🇺
⏱️ Completing this anonymous #survey takes under 5 minutes. 👇
⏱️ Completing this anonymous #survey takes under 5 minutes. 👇
Omnibus - First Feedback
Thank you for sharing your views with us!
survey.noyb.eu
December 7, 2025 at 11:00 AM
📝 #DigitalOmnibus - First Feedback 💭 Are you a DPO, lawyer or other #privacy professional? We would like to know your first impressions of the proposed changes to the #GDPR. 🇪🇺
⏱️ Completing this anonymous #survey takes under 5 minutes. 👇
⏱️ Completing this anonymous #survey takes under 5 minutes. 👇
There is a tremendous difference between parcels you can’t look into and modern online platforms.
The time of neutral platforms has come and gone, now they fully control the displaying and engagement for profit or their interests. Legal privileges aren’t appropriate anymore for that.
The time of neutral platforms has come and gone, now they fully control the displaying and engagement for profit or their interests. Legal privileges aren’t appropriate anymore for that.
Finally had a chance to write up the CJEU's Russmedia ruling which appears to make it literally *impossible* to run a website in the EU that allows any user content. I just don't see how compliance is possible. At all. Hat tip to @daphnek.bsky.social for calling it to my attention.
EU’s Top Court Just Made It Literally Impossible To Run A User-Generated Content Platform Legally
The Court of Justice of the EU—likely without realizing it—just completely shit the bed and made it effectively impossible to run any website in the entirety of the EU that hosts user-generated…
The Court of Justice of the EU—likely without realizing it—just completely shit the bed and made it effectively impossible to run any website in the entirety of the EU that hosts user-generated…
December 5, 2025 at 3:42 PM
There is a tremendous difference between parcels you can’t look into and modern online platforms.
The time of neutral platforms has come and gone, now they fully control the displaying and engagement for profit or their interests. Legal privileges aren’t appropriate anymore for that.
The time of neutral platforms has come and gone, now they fully control the displaying and engagement for profit or their interests. Legal privileges aren’t appropriate anymore for that.
Reposted by Markus Sullivan
📝 #DigitalOmnibus - First Feedback 📝
💭 Are you a #DPO, #lawyer or other #privacy professional? We would like to know your first impressions of the proposed changes to the #GDPR. 🇪🇺
⏱️ Completing this anonymous #survey takes under 5 minutes. 👉 survey.noyb.eu/index.php?r=...
💭 Are you a #DPO, #lawyer or other #privacy professional? We would like to know your first impressions of the proposed changes to the #GDPR. 🇪🇺
⏱️ Completing this anonymous #survey takes under 5 minutes. 👉 survey.noyb.eu/index.php?r=...
December 5, 2025 at 10:00 AM
📝 #DigitalOmnibus - First Feedback 📝
💭 Are you a #DPO, #lawyer or other #privacy professional? We would like to know your first impressions of the proposed changes to the #GDPR. 🇪🇺
⏱️ Completing this anonymous #survey takes under 5 minutes. 👉 survey.noyb.eu/index.php?r=...
💭 Are you a #DPO, #lawyer or other #privacy professional? We would like to know your first impressions of the proposed changes to the #GDPR. 🇪🇺
⏱️ Completing this anonymous #survey takes under 5 minutes. 👉 survey.noyb.eu/index.php?r=...
Impartiality and independence are essential to roles in the second line of defense because without them the role loses credibility and effectiveness. The level of hostility and opposition the requirement faces is a strong indicator of organisational maturity: high hostility signals low maturity.
December 4, 2025 at 7:50 PM
Impartiality and independence are essential to roles in the second line of defense because without them the role loses credibility and effectiveness. The level of hostility and opposition the requirement faces is a strong indicator of organisational maturity: high hostility signals low maturity.
9 December 2025, 16:00 – Online
Deep dive on “Purpose” under the GDPR with Dr. Johannes Zhou, author of "Der Grundsatz der Zweckbindung"
iapp.org/connect/comm...
Deep dive on “Purpose” under the GDPR with Dr. Johannes Zhou, author of "Der Grundsatz der Zweckbindung"
iapp.org/connect/comm...
Virtual Munich KnowledgeNet: 9 Dec. 2025
This event will be held virtually with no in-person component and will not be recorded. Instructions on how to view this virtual presentation will be sent to registrants upon registration and 1-2 days...
iapp.org
December 4, 2025 at 6:56 PM
9 December 2025, 16:00 – Online
Deep dive on “Purpose” under the GDPR with Dr. Johannes Zhou, author of "Der Grundsatz der Zweckbindung"
iapp.org/connect/comm...
Deep dive on “Purpose” under the GDPR with Dr. Johannes Zhou, author of "Der Grundsatz der Zweckbindung"
iapp.org/connect/comm...
Reposted by Markus Sullivan
𝗗𝗦𝗚𝗩𝗢-𝗥𝗲𝗳𝗼𝗿𝗺: 𝗞𝗲𝗶𝗻𝗲 𝗜𝗻𝗳𝗼𝗿𝗺𝗮𝘁𝗶𝗼𝗻𝘀𝗽𝗳𝗹𝗶𝗰𝗵𝘁𝗲𝗻 𝗳ü𝗿 𝗛𝗮𝗻𝗱𝘄𝗲𝗿𝗸𝗲𝗿, 𝗩𝗲𝗿𝗲𝗶𝗻𝗲 𝘂𝗻𝗱 „𝗻𝗶𝗰𝗵𝘁 𝗱𝗮𝘁𝗲𝗻𝗶𝗻𝘁𝗲𝗻𝘀𝗶𝘃𝗲“ 𝗧ä𝘁𝗶𝗴𝗸𝗲𝗶𝘁𝗲𝗻? 𝗩ö𝗹𝗹𝗶𝗴 𝗺𝗶𝘀𝘀𝗴𝗹ü𝗰𝗸𝘁𝗲𝗿 𝗩𝗲𝗿𝘀𝘂𝗰𝗵 𝗱𝗲𝗿 𝗞𝗼𝗺𝗺𝗶𝘀𝘀𝗶𝗼𝗻.
www.delegedata.de/dsgvo-reform...
#DSGVO #Datenschutz #GDPR #DSGVOReform
www.delegedata.de/dsgvo-reform...
#DSGVO #Datenschutz #GDPR #DSGVOReform
December 1, 2025 at 9:33 AM
𝗗𝗦𝗚𝗩𝗢-𝗥𝗲𝗳𝗼𝗿𝗺: 𝗞𝗲𝗶𝗻𝗲 𝗜𝗻𝗳𝗼𝗿𝗺𝗮𝘁𝗶𝗼𝗻𝘀𝗽𝗳𝗹𝗶𝗰𝗵𝘁𝗲𝗻 𝗳ü𝗿 𝗛𝗮𝗻𝗱𝘄𝗲𝗿𝗸𝗲𝗿, 𝗩𝗲𝗿𝗲𝗶𝗻𝗲 𝘂𝗻𝗱 „𝗻𝗶𝗰𝗵𝘁 𝗱𝗮𝘁𝗲𝗻𝗶𝗻𝘁𝗲𝗻𝘀𝗶𝘃𝗲“ 𝗧ä𝘁𝗶𝗴𝗸𝗲𝗶𝘁𝗲𝗻? 𝗩ö𝗹𝗹𝗶𝗴 𝗺𝗶𝘀𝘀𝗴𝗹ü𝗰𝗸𝘁𝗲𝗿 𝗩𝗲𝗿𝘀𝘂𝗰𝗵 𝗱𝗲𝗿 𝗞𝗼𝗺𝗺𝗶𝘀𝘀𝗶𝗼𝗻.
www.delegedata.de/dsgvo-reform...
#DSGVO #Datenschutz #GDPR #DSGVOReform
www.delegedata.de/dsgvo-reform...
#DSGVO #Datenschutz #GDPR #DSGVOReform
Interesting example of unintended consequences. I completely get how problematic access request can be, however, they somehow also scale with how problematic processing and retention is.
Perhaps in the end we went a little of the deep end with keeping data, and this shows on these requests.
Perhaps in the end we went a little of the deep end with keeping data, and this shows on these requests.
Data Donation Research Must Be Protected: Researchers voice concerns about the proposed GDPR Omnibus. Administrative efficiency cannot justify undermining democratic accountability & science freedom dsa40collaboratory.eu/open-letter-...
Open Letter: Omnibus – DSA 40 Collaboratory
dsa40collaboratory.eu
December 4, 2025 at 6:35 PM
Interesting example of unintended consequences. I completely get how problematic access request can be, however, they somehow also scale with how problematic processing and retention is.
Perhaps in the end we went a little of the deep end with keeping data, and this shows on these requests.
Perhaps in the end we went a little of the deep end with keeping data, and this shows on these requests.
Reposted by Markus Sullivan
Hier ist der Koalitionsvertrag (Entwurf) zwischen CDU/CSU/SPD: fragdenstaat.de/dokumente/25...
Koalitionsvertrag CDU/CSU/SPD 2025 (Entwurf)
fragdenstaat.de
April 9, 2025 at 1:05 PM
Hier ist der Koalitionsvertrag (Entwurf) zwischen CDU/CSU/SPD: fragdenstaat.de/dokumente/25...
GDPR reform discussions are still shaped by lobbyists, not those enforcing it daily. Any change (good or bad) demands massive effort, prolongs uncertainty, and undoes hard-won harmonization.
Real improvement should focus on true harmonization across member states—not chasing perfection.
Real improvement should focus on true harmonization across member states—not chasing perfection.
Voss and Schrems team up to propose three-layered GDPR revision - Euractiv
But revising the EU's landmark data privacy regulation could be akin to re-opening Pandora's box.
www.euractiv.com
March 7, 2025 at 8:10 AM
GDPR reform discussions are still shaped by lobbyists, not those enforcing it daily. Any change (good or bad) demands massive effort, prolongs uncertainty, and undoes hard-won harmonization.
Real improvement should focus on true harmonization across member states—not chasing perfection.
Real improvement should focus on true harmonization across member states—not chasing perfection.
Join Us at the #IAPP #KnowledgeNet special edition - 𝐇𝐚𝐦𝐛𝐮𝐫𝐠 𝐌𝐞𝐞𝐭𝐬 𝐁𝐚𝐯𝐚𝐫𝐢𝐚: 𝐓𝐡𝐞 𝐭𝐰𝐨 𝐂𝐨𝐦𝐦𝐢𝐬𝐬𝐢𝐨𝐧𝐞𝐫𝐬
You will also have the opportunity to ask if the Franzbrezel is a thing and whether this demonstrates that AI went too far.
📝 𝗥𝗲𝗴𝗶𝘀𝘁𝗿𝗮𝘁𝗶𝗼𝗻: my.iapp.org/nc__event?id...
🗓️ 𝗗𝗮𝘁𝗲: 09.10.2024 13:00 CEST
You will also have the opportunity to ask if the Franzbrezel is a thing and whether this demonstrates that AI went too far.
📝 𝗥𝗲𝗴𝗶𝘀𝘁𝗿𝗮𝘁𝗶𝗼𝗻: my.iapp.org/nc__event?id...
🗓️ 𝗗𝗮𝘁𝗲: 09.10.2024 13:00 CEST
March 7, 2025 at 7:13 AM
Join Us at the #IAPP #KnowledgeNet special edition - 𝐇𝐚𝐦𝐛𝐮𝐫𝐠 𝐌𝐞𝐞𝐭𝐬 𝐁𝐚𝐯𝐚𝐫𝐢𝐚: 𝐓𝐡𝐞 𝐭𝐰𝐨 𝐂𝐨𝐦𝐦𝐢𝐬𝐬𝐢𝐨𝐧𝐞𝐫𝐬
You will also have the opportunity to ask if the Franzbrezel is a thing and whether this demonstrates that AI went too far.
📝 𝗥𝗲𝗴𝗶𝘀𝘁𝗿𝗮𝘁𝗶𝗼𝗻: my.iapp.org/nc__event?id...
🗓️ 𝗗𝗮𝘁𝗲: 09.10.2024 13:00 CEST
You will also have the opportunity to ask if the Franzbrezel is a thing and whether this demonstrates that AI went too far.
📝 𝗥𝗲𝗴𝗶𝘀𝘁𝗿𝗮𝘁𝗶𝗼𝗻: my.iapp.org/nc__event?id...
🗓️ 𝗗𝗮𝘁𝗲: 09.10.2024 13:00 CEST
So I wrote something on the placement of DPOs under GDPR in the IIA three lines because this practical issue has way too few published opinions.
I'd love any feedback on how different setups played out for you.
www.linkedin.com/posts/markus...
I'd love any feedback on how different setups played out for you.
www.linkedin.com/posts/markus...
November 4, 2023 at 1:58 PM
So I wrote something on the placement of DPOs under GDPR in the IIA three lines because this practical issue has way too few published opinions.
I'd love any feedback on how different setups played out for you.
www.linkedin.com/posts/markus...
I'd love any feedback on how different setups played out for you.
www.linkedin.com/posts/markus...
“It’s also important that we continue to comply with all relevant legislation. For example the GDPR and other requirements, there are no derogation from that in my proposal,”
Leading by example and all, in particular when it comes to transparency
#TeamDatenschutz
Leading by example and all, in particular when it comes to transparency
#TeamDatenschutz
EU commissioner sidesteps MEPs' questions about CSAM proposal microtargeting | TechCrunch
The European Union's home affairs commissioner, Ylva Johansson, has confirmed the Commission is investigating whether or not it broke recently updated
techcrunch.com
October 31, 2023 at 7:04 AM
“It’s also important that we continue to comply with all relevant legislation. For example the GDPR and other requirements, there are no derogation from that in my proposal,”
Leading by example and all, in particular when it comes to transparency
#TeamDatenschutz
Leading by example and all, in particular when it comes to transparency
#TeamDatenschutz