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Wednesday, March 10, 2021
The French Supervisory Authority (CNIL) wrapped up 2020 with a EUR 20,000 fine against NESTOR, a French food preparation and delivery company catering to office employees (see full decision here in French).
1
Various breaches of the General Data Protection Regulation (GDPR)
2 and the ePrivacy Directive regarding the processing of prospects and clients’ personal data were highlighted by the CNIL, most notably:
3
4 whether:
Upon indirect collection through external sources;
The failure to properly address data subjects’ access requests (DSAR).
5
While the fine is rather limited in view of the maximum potential amount of EUR 20 million or four percent of the turnover (whichever the greater), this decision remains an opportunity to look at web scraping and direct marketing practices, which are rapidly developing.
[co-author: Alexia Montagnon]
The French Supervisory Authority has set 31 March 2021 as the end of the “reasonable period” to bring websites and mobile applications into compliance.
Following the adoption and publication of its updated guidelines along with practical recommendations on the use of cookies on 1 October 2020 (see our alert on the subject here), the French Supervisory Authority (CNIL) reaffirmed on 4 February 2021 the need for private and public players to comply with the new obligations regarding cookies and other tracers (together, Cookies).
1
To make its action plan on online advertising effective and in view targeting of the deficiencies witnessed in both the public and private sectors, the CNIL set a specific deadline for the implementation of its recommendation: 31 March 2021.
The French Supervisory Authority has set 31 March 2021 as the end of the “reasonable period” to bring websites and mobile applications into compliance. the French Supervisory Authority CNIL reaffirmed the need for private and public players to comply with new obligations on cookies and other tracers
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