Website operators should take note that they may be breaking the law if they force visitors to accept cookies or pay for access. The latest guidance on website cookie walls, published on 16 May 2022 by the French data protection authority ('CNIL'), sheds some light on criteria for assessing the legality of cookie walls¹. Odia Kagan, Partner and Chair of GDPR Compliance & International Privacy at Fox Rothschild LLP, breaks down the guidance into practical steps for website operators.

Managing data flows involving suppliers and vendors is one of the most challenging tasks for data controllers in practice. Preliminarily, this requires a detailed understanding of various legal obligations resulting from different laws. In addition, the development of case law on the national and EU level needs to be monitored and already implemented measures frequently adjusted on that basis. Finally, organisational and negotiation skills are an absolute must-have in order to balance business interests and commercial impacts. Part 3 of the implementation series explored data mapping, and in part 4, Axel Anderl and Nino Tlapak, from DORDA Rechtsanwälte GmbH, discuss vender management best practices and its nuances.