GDPR Article 35 and Article 25 Square Off

For those not buried in the details of the European General Data Protection Regulation (GDPR), there is often confusion about be the differences between Data Protection Impact Assessments (Article 35) and Data Protection by Design and Default (Article 25). Many people assume that DPIAs, as the impact assessments are called, are synonymous with with Data […]

Lawful Basis under GDPR: Performance of a Contract

The newly enacted General Data Protection Regulation (GDPR) in the European Union provides for six lawful bases for processing data. Just as a baseline for readers who may not be familiar with the GDPR, in general processing is prohibited unless you have a lawful basis.  Article 6 of the regulation provides for the list of […]

When is a hack a hack?

This was cross-posted from LinkedIn.   The recent kerfuffle around Ethereum and the #DAO “hack” is just another in a long list of events which illustrate the difficultly in defining the term “hacking.”  For those unfamiliar with Ethereum and the DAO, a little background. Ethereum is a blockchain technology which expanded on the idea of […]

Agency Information Collection Activities: Arrival and Departure Record (Forms I-94 and I-94W) and Electronic System for Travel Authorization

June 5th, 2016 U.S. Customs and Border Protection Attn: Paperwork Reduction Act Officer Regulations and Rulings Office of Trade 90 K Street NE. 10th Floor Washington, DC 20229-1177. I am writing in response to the notice published in Federal Register on 6/23/2016 entitled “Agency Information Collection Activities: Arrival and Departure Record (Forms I-94 and I-94W) […]