News Personal data

In Circular No. 6519/SG [1] dated 5 February 2026, Prime Minister Sébastien Lecornu sets out the framework for the State’s digital public procurement and reiterates the requirement to rely on the SecNumCloud qualification for hosting data of particular sensitivity, including health data. The circular establishes digital sovereignty as the...

In its decision of 10 February 2026, WhatsApp Ireland Ltd v European Data Protection Board (Case C-97/23 P) [2], the Court of Justice of the European Union (“CJEU”) held that a decision of the European Data Protection Board (“EDPB”) constitutes an act that may be challenged before the EU courts. In this case, following complaints relating to data...

In 2023, the CNIL established a dedicated service for the economic analysis of issues related to personal data, with the aim of strengthening its expertise and informing its decisions through impact assessments, sectoral analyses, and quantitative studies evaluating the economic effects of its rulings. It is indeed essential for a data...

On 8 January 2026, the French data protection authority (CNIL) issued two rulings against Free Mobile [4] and Free [5] (the “Companies”), imposing fines of €27 million and €15 million respectively for various breaches of the General Data Protection Regulation (GDPR). In this case, the Companies were alerted in October 2024 that an attacker had...

On 27 December 2025, Decree No. 2025-1335 [9] (the “Decree”) was published in the French Official Journal. In particular, this Decree : sets out the arrangements for monitoring and supervising compliance with the periodic certification obligation applicable to healthcare professionals ; specifies the procedures applicable in the event of a...

DELSOL Avocats is delighted to have been included in 35 categories in the first edition of the Best Law Firms™ – France rankings (by Best Lawyers). Biotechnology and Life Sciences Practice Construction Law Corporate Law Information Technology Law Insolvency and Reorganization Law Litigation Mergers and Acquisitions Law Private Equity Law Real...

In a judgment dated September 4th, 2025 [13] , the Court of Justice of the European Union (CJEU) provided major clarifications regarding the concept of personal data. In this case, the Court was asked to rule, in particular, on the qualification, in terms of the definition of personal data, of comments made by individuals to a controller (the...

On 9 September, in accordance with the Regulation on artificial intelligence (“AI Act”) [14], the French Ministry of Economy and Finance unveiled the list of national authorities responsible for artificial intelligence and the division of their respective powers [15]. The diagram presented by Bercy distinguishes between the authorities...

In a ruling dated September 3, 2025 [16] , the General Court of the European Union (“GCEU”) dismissed the appeal brought by the French member of parliament Philippe Latombe, seeking annulment of the “Data Privacy Framework” established by the European Commission’s adequacy decision of July 10, 2023, allowing the transfer of personal data from the...

DELSOL Avocats has advised the AGORiA Santé consortium, in partnership with BIOGROUP, on obtaining the CNIL’s (French data protection authoritys) first authorization to combine biology and SNDS (French national health data system) data in a health data warehouse. Created in 2021, the AGORIA Santé consortium comprises AstraZeneca France, Takeda...

On 10 July 2025, the code of practice (“Code”) [18] for general purpose artificial intelligence models (“GPAI models”) was published. Provided for in Article 56 of Regulation 2024/1689 on Artificial Intelligence (“AI Act”), the Code forms part of the regulation’s phased implementation and is intended to help GPAI model providers comply with their...

On June 26th, 2025, the French Data Protection Authority (CNIL) announced the launch of the Privacy Auditing of AI Models (PANAME) project — which it will lead and legally frame — with the goal of developing a tool that can test the confidentiality of artificial intelligence models (“AI Model(s)”). This initiative comes against the backdrop of EU...

On July 1st 2025, the Minister for Health and Access to Care, Yannick Neuder, presented the national strategy for artificial intelligence (AI) and healthcare data [21] ("Strategy") at an exceptional Strategic Committee meeting. Set up to take advantage of the development of AI in the healthcare field (e.g., improving the quality of care,...

In a ruling dated June 18, 2025 [24], the Social Chamber of the Court of Cassation held that an employee’s right of access to his professional emails covered not only metadata but also the content of the emails. Called upon to rule on the scope of the right of access in a dispute between an employee and his employer in the context of his...

On June 19, 2025, the French data protection authority (CNIL) published two new practical guidelines [27] [28] detailing its recommendations regarding the use of legitimate interest as a legal basis for developing artificial intelligence systems (“AIS”), particularly in cases involving the harvesting of data available online (web scraping)....

On June 6, 2025, the European Commission launched a public consultation to gather feedback from stakeholders (e.g. providers and deployers of high-risk AI systems, industry organisations, independent experts, public authorities) on the implementation of the provisions applicable to high-risk AI systems (“Consultation”), as set out in Regulation...

In a decision dated May 15, 2025 [31], the CNIL imposed a fine on the company SOLOCAL MARKETING SERVICES (“Solocal company”) for failing to comply with regulations related to commercial prospecting and for breaching the obligation to demonstrate data subjects’ consent to the processing of their data. Solocal company, which operates in the field...

DELSOL Avocats advised the Centre Hospitalier Intercommunal Toulon - La Seyne-sur-Mer (CHITS) on the takeover of the Sainte-Marguerite clinic in Hyères (south of France) by Almaviva Santé, a group specialising in private hospital services in France and owned by the Kuwaiti Wren House fund. This takeover is part of a disposal plan approved by...

The magazine Le Point has published its ranking of law firms in France, which is based on recommendations. General counsels were able to rate the firms they work with and lawyers were able to indicate which firms they would recommend to their clients. DELSOL Avocats’ expertise is recommended in Compliance Healthcare law Commercial, business...