[{"titre":"i-Dressup and a data security mess-up","id":3203250,"pubDate":"Thu, 08 Oct 2026 08:06:59 +0200","description":"i-Dressup and a data security mess-up lfair April 24, 2019 | 3:08PM i-Dressup and a data security mess-up By Lesley Fair Kids love to play dress-up, but parents wouldn’t want them rummaging through the attic or climbing to the top shelf of the wardrobe without permission and proper supervision. The i-Dressup.com website offered users – including children – a virtual way to play dress-up and design clothes without those potential dangers. But according to an FTC complaint, Unixiz, Inc. , the company behind i-Dressup, violated the Children’s Online Privacy Protection Act in ways that created different kinds of risks. COPPA puts two separate sets of protections in place to help keep parents in control of personal information collected from their kids online. First, COPPA-covered companies must clearly disclose their information policies and get parental consent before collecting personal information from children under 13. Second, companies must provide reasonable and appropriate security for the data they collect. According to an FTC settlement, i-Dressup fell short on both COPPA requirements. The complaint alleges i-Dressup failed to provide sufficient notice on its site of the information it collected online from kids, how it used it, its disclosure practices, and other specifics required by the COPPA Rule. The company’s direct notices to parents were deficient, too. Among other things, they didn’t include the COPPA-required statement that if parents don’t provide consent within a reasonable time, i-Dressup will delete their online contact information from its records. Stick with the story because that failure turned out to be particularly troubling. In addition to letting users play online games, i-Dressup featured a community where they could “explore their creativity and fashion sense with unique personal profiles” and interact with others. To register, i-Dressup required people to submit a user name, password, birthdate, and email address. If the birthdate indicated the person was under 13, the email field changed to “Parent’s Email.” Once the under-13 user filled in the required fields and clicked “Join Now,” i-Dressup collected the personal information and sent a message to the address entered into the Parent’s Email field. The person receiving the email could consent by clicking the “Activate Now!” button. However, if the parent didn’t give consent, i-Dressup retained the personal information it had collected from the child online. The FTC says the company’s failure to delete that information violated Section 312.5(c)(1) of the COPPA Rule. In addition to violating COPPA’s parental consent provisions, i-Dressup allegedly violated the Rule’s data security requirements . According to the FTC, i-Dressup stored and transmitted users’ personal information (including passwords) in plain text. In addition, the company failed to perform network vulnerability testing of its network, even for well-known threats like SQL attacks; it didn’t implement an intrusion detection and prevention system; and it didn’t monitor for potential security incidents. The upshot? The company learned that a hacker had gained entry to its network and accessed information about 2.1 million users, including approximately 245,000 users who indicated they were under 13. To settle the case , i-Dressup and its owners will pay a $35,000 civil penalty. They’re also prohibited from violating COPPA in the future, and can’t sell, share, or collect any personal information until they implement a comprehensive data security program and get independent biennial assessments. In addition, they’ll have to provide the FTC with an annual certification of compliance. The message for sites and operators covered by COPPA is that an effective system of parental consent is only the first step toward compliance. Section 312.8 of the COPPA Rule also requires you to “establish and maintain reasonable","source":"FTC USA Business Blog Posts","url":"https://www.ftc.gov/business-guidance/blog/2019/04/i-dressup-data-security-mess"},{"titre":"CEF 2026: EDPB launches coordinated enforcement action on transparency and information obligations under the GDPR","pubDate":"Thu, 19 Mar 2026 14:12:59 +0100","id":2769535,"description":"Brussels, 19 March - The EDPB has launched its Coordinated Enforcement Framework (CEF) action for 2026*. Following a year-long coordinated action on the right to erasure in 2025 , the CEF's focus this year will shift to compliance with the obligations of transparency and information under the GDPR . The GDPR ensures that individuals are informed when their data is being processed (under Art. 12, 13 and 14). This right to be informed is a core element of transparency and ensures that individuals have more control over their data. Next steps During 2026, 25 Data Protection Authorities (DPAs) across Europe will take part in this initiative. They will look closely to assess the compliance of controllers with their transparency obligations under the GDPR. Participating DPAs will soon contact controllers from different sectors across Europe, either through enforcement actions or fact-finding exercises. In the latter case, they might also decide to undertake additional follow-up actions if needed. During the second half of the year, participating DPAs will share and discuss their findings together, with a view to aggregate the results of their national actions and generate deeper insight into the topic. A consolidated report will then be drafted and submitted for adoption by the EDPB, allowing for targeted follow-ups on both national and EU levels. Background The CEF is a key action of the EDPB under its 2024-2027 Strategy , aimed at streamlining enforcement and cooperation among DPAs. In 2023, the EDPB published the report on its first coordinated action on the use of cloud-based services by the public sector . In 2024, the EDPB also published the report on the outcome of the second coordinated action on the designation and position of Data Protection Officers . In 2025, the EDPB issued the report on its third coordination action on the implementation of the right of access . In 2026, the EDPB has adopted a report on its Coordinated Enforcement Framework (CEF) action on the right to be forgotten (Art.17 GDPR) .   Note to editors: *The Board selected this topic during its October 2025 plenary","source":"EDPB News","url":"https://www.edpb.europa.eu/news/news/2026/cef-2026-edpb-launches-coordinated-enforcement-action-transparency-and-information_en"},{"url":"https://www.edpb.europa.eu/news/news/2025/french-sa-fines-solocal-eu900-000_en","source":"EDPB News","description":"Background information Date of final decision: 15 May 2025 National case Controller:  SOLOCAL MARKETING SERVICES Legal Reference(s): Article 7 (Conditions for consent), Article 6 (Lawfulness of processing) Decision: administrative fine and an order to cease electronic commercial prospecting in the absence of valid consent, together with a penalty of €10 000 per day overdue after a period of 9 months Key words: administrative fine, consent,  unsolicited communication   Summary of the Decision Origin of the case   As the French Supervisory Authority (SA) made commercial prospecting a priority topic for investigations in 2022, it focused on the practices of professionals in the sector, particularly those who resell data, including the many intermediaries in this ecosystem known as data brokers. The French SA carried out investigations on SOLOCAL MARKETING SERVICES which got prospect data mainly from data brokers, publishers of game contests and product testing sites (these actors are the first links in the chain, the primary collectors, who are responsible for collecting prospect data). SOLOCAL MARKETING SERVICES used this data to operate commercial prospecting by SMS or e-mail to individuals concerned, on behalf of its advertiser customer. It may also pass on some of this data to its customers, so that they can carry out their own commercial prospecting by telephone or post. Key Findings  Failure to comply with the obligation to obtain the consent of individuals to receive commercial prospecting by electronic means (Article L.34-5 of the French Post and Electronic Communications Code): The restricted committee considered that the misleading appearance of the forms used by data brokers made it impossible to obtain free and unambiguous consent, in compliance with the requirements of the GDPR, which would have formed the basis for the prospecting operations carried out by the company. Failure to demonstrate that the data subject has consented to processing of his or her personal data (Article 7 of the GDPR): The company failed to provide the French SA with proof of consent from individuals whose data has been transferred to it by one of its main suppliers. As a result, the French SA was unable to examine the collection forms used by this supplier and, therefore, the validity of the consent of the data subjects.   Decision  Based on the findings of the inspection, the restricted committee – the French SA body responsible for issuing sanctions – considered that the company had failed to comply with obligations under the French Post and Electronic Communications Code (CPCE) and the General Data Protection Regulation (GDPR) regarding the collection and proof of consent.  It imposed on SOLOCAL MARKETING SERVICES:  a €900 000 fine which was made public; and an order to cease electronic commercial prospecting in the absence of valid consent, together with a penalty of €10 000 per day overdue after a period of 9 months.  The amount of this fine takes into account the very large number of people concerned (several million), the company's historical position on the market, the financial benefit derived from the breaches, and the measures taken by the company to comply with some of its obligations since the checks were carried out. For further information:  •  Courtiers en données : sanction de 900 000 euros à l’encontre de la société SOLOCAL MARKETING SERVICES (French) •  Data brokers: SOLOCAL MARKETING SERVICES fined €900,000  (English)","id":2170441,"pubDate":"Tue, 10 Jun 2025 09:51:20 +0200","titre":"The French SA fines SOLOCAL €900 000"},{"id":2130472,"pubDate":"Wed, 21 May 2025 15:52:14 +0200","titre":"The French SA fines SOLOCAL 900 000 €","description":"Background information Date of final decision: 15 May 2025 National case Controller:  SOLOCAL MARKETING SERVICES Legal Reference(s): Article 7 (Conditions for consent), Article 6 (Lawfulness of processing) Decision: administrative fine and an order to cease electronic commercial prospecting in the absence of valid consent, together with a penalty of 10 000 € per day overdue after a period of 9 months Key words: administrative fine, consent,  unsolicited communication   Summary of the Decision Origin of the case   As the French Supervisory Authority (SA) made commercial prospecting a priority topic for investigations in 2022, it focused on the practices of professionals in the sector, particularly those who resell data, including the many intermediaries in this ecosystem known as data brokers. The French SA carried out investigations on SOLOCAL MARKETING SERVICES which got prospect data mainly from data brokers, publishers of game contests and product testing sites (these actors are the first links in the chain, the primary collectors, who are responsible for collecting prospect data). SOLOCAL MARKETING SERVICES used this data to operate commercial prospecting by SMS or e-mail to individuals concerned, on behalf of its advertiser customer. It may also pass on some of this data to its customers, so that they can carry out their own commercial prospecting by telephone or post. Key Findings  Failure to comply with the obligation to obtain the consent of individuals to receive commercial prospecting by electronic means (Article L.34-5 of the French Post and Electronic Communications Code): The restricted committee considered that the misleading appearance of the forms used by data brokers made it impossible to obtain free and unambiguous consent, in compliance with the requirements of the GDPR, which would have formed the basis for the prospecting operations carried out by the company. Failure to demonstrate that the data subject has consented to processing of his or her personal data (Article 7 of the GDPR): The company failed to provide the French SA with proof of consent from individuals whose data has been transferred to it by one of its main suppliers. As a result, the French SA was unable to examine the collection forms used by this supplier and, therefore, the validity of the consent of the data subjects.   Decision  Based on the findings of the inspection, the restricted committee – the French SA body responsible for issuing sanctions – considered that the company had failed to comply with obligations under the French Post and Electronic Communications Code (CPCE) and the General Data Protection Regulation (GDPR) regarding the collection and proof of consent.  It imposed on SOLOCAL MARKETING SERVICES:  a 900 000 € fine which was made public; and an order to cease electronic commercial prospecting in the absence of valid consent, together with a penalty of 10 000 € per day overdue after a period of 9 months.  The amount of this fine takes into account the very large number of people concerned (several million), the company's historical position on the market, the financial benefit derived from the breaches, and the measures taken by the company to comply with some of its obligations since the checks were carried out. For further information:  •   Courtiers en données : sanction de 900 000 euros à l’encontre de la société SOLOCAL MARKETING SERVICES (French) •   Data brokers: SOLOCAL MARKETING SERVICES fined €900,000  (English)","url":"https://www.edpb.europa.eu/news/news/2025/french-sa-fines-solocal-900-000-eu_en","source":"EDPB News"},{"description":"Brussels, 20 January - The European Data Protection Board (EDPB) has adopted a report on the implementation of the right of access by controllers . The report summarises the outcome of a series of coordinated national actions carried out in 2024 under the Coordinated Enforcement Framework (CEF). It lists the issues that were observed for some controllers, along with a series of recommendations to help them implement the right of access. A central element is controllers’ awareness of the EDPB Guidelines 01/2022 on data subjects rights – Right of access and whether these guidelines were followed in practice. EDPB Deputy Chair Zdravko Vukíc said: “The CEF is a valuable initiative that helps strengthen the cooperation among Data Protection Authorities (DPAs): by tackling selected topics in a coordinated fashion, they achieve greater efficiency and more consistency. How controllers implement the right of access lies at the heart of data protection and it is one of the most frequently exercised data subject rights.” Throughout 2024, 30 DPAs across Europe launched coordinated investigations into the compliance of controllers with the right of access, by opening formal investigations, assessing whether a formal investigation was warranted and/or carrying out fact-finding exercises.  A total of 1,185 controllers, consisting of small and medium-sized enterprises (SMEs) and big companies active in different industries and fields, as well as various types of public entities, responded to the action. Areas of improvement and main challenges The results suggest that more awareness raising about Guidelines 01/2022 is necessary , both at national and EU level, as the guidelines help controllers implement the right of access, explain how exercising this right can be made easier, and list the exceptions and limitations of the right to access. As a result of the 2024 CEF action, seven challenges were identified. One of them is the lack of documented internal procedures to handle access requests. In addition, inconsistent and excessive interpretations of the limits to the right of access were also observed, such as overly relying on certain exceptions to automatically refuse access requests. Another example is the barriers that individuals could encounter when exercising their right of access, such as  formal requirements or being requested to provide excessive identification documents. For each challenge identified, the report provides a list of non-binding recommendations to be taken into account by controllers and DPAs. Positive findings Despite the existing challenges, two thirds of participating DPAs evaluated the level of compliance of responding controllers with respect to the right of access from ‘average’ to ‘high’. One important factor identified as having an impact on the level of compliance was the volume of access requests received by controllers, as well as the size of the organisation. More specifically, large-sized controllers or controllers receiving more requests were more likely to reach a higher level of compliance than small organisations with less resources. Positive findings were observed across Europe. These include the implementation of best practices by controllers, such as user-friendly online forms enabling individuals to submit an access request easily as well as self-service systems to allow individuals to autonomously download their personal data in a few clicks and at any time. Background and next steps The CEF is a key action of the EDPB under its 2024-2027 Strategy, aimed at streamlining enforcement and cooperation among DPAs.  In the past three years, two previous CEF actions were carried out. The results of these national actions are aggregated and analysed together to generate deeper insight into the topic and allowing for targeted follow-up on both national and EU level. In 2023, the EDPB published the report on its first coordinated action on the use of cloud-based services by the public sector . In 2024, the EDPB also published the","titre":"CEF 2024: EDPB identifies challenges to the full implementation of the right of access","pubDate":"Mon, 20 Jan 2025 15:49:16 +0100","id":1857297,"source":"EDPB News","url":"https://www.edpb.europa.eu/news/news/2025/cef-2024-edpb-identifies-challenges-full-implementation-right-access_en"},{"id":1792119,"pubDate":"Wed, 18 Dec 2024 15:47:16 +0100","titre":"EDPB opinion on AI models: GDPR principles support responsible AI","description":"Brussels, 18 December - The European Data Protection Board (EDPB) has adopted an opinion* on the use of personal data for the development and deployment of AI models . This opinion looks at 1) when and how AI models can be considered anonymous, 2) whether and how legitimate interest can be used as a legal basis for developing or using AI models, and 3) what happens if an AI model is developed using personal data that was processed unlawfully. It also considers the use of first and third party data. The opinion was requested by the Irish Data Protection Authority (DPA) with a view to seeking Europe-wide regulatory harmonisation. To gather input for this opinion, which deals with fast-moving technologies that have an important impact on society, the EDPB organised a stakeholders’ event and had an exchange with the EU AI Office. EDPB Chair Talus said: “AI technologies may bring many opportunities and benefits to different industries and areas of life. We need to ensure these innovations are done ethically, safely, and in a way that benefits everyone. The EDPB wants to support responsible AI innovation by ensuring personal data are protected and in full respect of the General Data Protection Regulation (GDPR).” Regarding anonymity , the opinion says that whether an AI model is anonymous should be assessed  on a case by case basis by the DPAs. For a model to be anonymous, it should be very unlikely (1) to directly or indirectly identify individuals whose data was used to create the model, and (2) to extract such personal data from the model through queries. The opinion provides a non-prescriptive and non-exhaustive list of methods to demonstrate anonymity. With respect to legitimate interest , the opinion provides general considerations that DPAs should take into account when they assess if legitimate interest is an appropriate legal basis for processing personal data for the development and the deployment of AI models. A three-step test helps assess the use of legitimate interest as a legal basis. The EDPB gives the examples of a conversational agent to assist users, and the use of AI to improve cybersecurity. These services can be beneficial for individuals and can rely on legitimate interest as a legal basis, but only if the processing is shown to be strictly necessary and the balancing of rights is respected. The opinion also includes a number of criteria to help DPAs assess if individuals may reasonably expect certain uses of their personal data. These criteria include: whether or not the personal data was publicly available, the nature of the relationship between the individual and the controller, the nature of the service, the context in which the personal data was collected, the source from which the data was collected, the potential further uses of the model, and whether individuals are actually aware that their personal data is online. If the balancing test shows that the processing should not take place because of the negative impact on individuals, mitigating measures may limit this negative impact. The opinion includes a non-exhaustive list of examples of such mitigating measures, which can be technical in nature, or make it easier for individuals to exercise their rights or increase transparency. Finally, when an AI model was developed with unlawfully processed personal data, this could have an impact on the lawfulness of its deployment, unless the model has been duly anonymised. Considering the scope of the request from the Irish DPA, the vast diversity of AI models and their rapid evolution, the opinion aims to give guidance on various elements that can be used for conducting a case by case analysis. In addition, the EDPB is currently developing guidelines covering more specific questions, such as web scraping. Note to editors: *An Article 64(2) opinion addresses a matter of general application or produces effects in more than one Member","url":"https://www.edpb.europa.eu/news/news/2024/edpb-opinion-ai-models-gdpr-principles-support-responsible-ai_en","source":"EDPB News"}]