History Repeats Itself: Implementation of EU Data Protection Legislation in the Accession Countries

Although the accession countries have been swift to implement the data protection and e-privacy directives, a large majority have failed to implement them correctly in a number of important respects. Ironically, the areas of greatest departure are the same areas the Commission identified last year as the areas where the original 15 Member States had also fallen down. In a number of cases, the deficiencies are so great that the EU Member States are vulnerable to enforcement action by the EU Commission for failure to implement the directives as required. Richard Cumbley and Tanguy Van Overstraeten of Linklaters explain.

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