Abstract
The Irish Data Protection Commission (DPC) regulates many of the top global technology companies and as such its decisions have a significant impact on the companies and on the many users of their platforms. This article examines a number of recent data breach decisions of the DPC and finds them forensic, focused, reasoned and formulaic in approach. The decisions deal with key General Data Protection Regulation (GDPR) provisions, notably on requirements for data breach notification and communication with data subjects. In a change of strategy earlier this year, the DPC no longer offers guidance to controllers dealing with a breach, as was its previous practice. Decisions such as these are likely to help fill that vacuum.
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