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Privacy

Legal analyses and updates on Privacy — by Mr. Dr. Antoinette Vlieger.

26 Jul 2026

The position of the Data Protection Officer

The Data Protection Officer must not receive instructions or be penalized for his work, is bound by a duty of confidentiality, and must not hold a second role that conflicts with his position.

26 Jul 2026

The resources required by the Data Protection Officer

The GDPR requires organizations not only to appoint a Data Protection Officer (DPO) but also to create the conditions necessary for them to effectively perform their duties. Part 1 on the DPO’s position: involvement, resources, and visibility.

13 Apr 2026

The Digital Omnibus and CJEU Scania

It is argued in various publications that the draft Digital Omnibus (concerning, among other things, amendments to the GDPR) would nullify the legal effect of the Scania judgment. However, a careful reading of the text suggests otherwise. The Commission is not proposing a nullification, but a demarcation of scope.

02 Jun 2025

The existing free flow of health data

The free movement of health data is not a novelty of the EHDS: it is enshrined in Article 1 of the GDPR, among other. Dr. Vlieger explains which rights scientists can already claim.

01 Jun 2025

The citizen service number ban and the EHDS

The prohibition on using the civil service number hinders medical-scientific research. Dr. Vlieger analyzes the legal knot and explains why the EHDS offers the opportunity to resolve this.

14 May 2025

GDPR, purpose limitation, science and corona

The GDPR principle of purpose limitation seems to be an obstacle to the reuse of health data for medical big data research. That is incorrect. Dr. Vlieger explains.

14 May 2025

What is a DPIA, what not?

When is a Data Protection Impact Assessment mandatory? And what is the role of the Data Protection Officer? Dr. Vlieger explains what a DPIA is and isn't.

30 Mar 2025

Pseudonymization and the GDPR

Are pseudonymous data personal data? Dr. Vlieger explains the relative concept based on case law of the European Court.