Author - Lianna Inthavong

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OAIC Publishes Updated Guidance on Facial Recognition Technology for Australia
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EU Digital Omnibus on AI Enters Into Force
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EDPB Adopts Common Data Breach Notification Template
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Washington State Enacts First-of-Its-Kind Chatbot Disclosure Law
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Mixed Blessings: Decision on Appeal by Bunnings Against Privacy Commissioner’s Determination Re the Use of Facial Recognition Technology
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New Zealand Privacy Law Amendment Act Passes
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UK Data Use and Access Bill Becomes Law
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AI Models May Be Trained With Publicly Available Data From Social Networks, Says the Higher Regional Court of Cologne (Decision of 23 May 2025, Ref. 15 Ukl. 2/25)
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Termination Button–Also Required for Agreements With Automatic Expiry and One-Time Payment
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Deployment of AI in the Workplace in France–The Importance of Consulting With the Work Forces

OAIC Publishes Updated Guidance on Facial Recognition Technology for Australia

By: Cameron Abbott, Rob Pulham, and Emre Cakmakcioglu

The Office of the Australian Information Commissioner (OAIC) has published updated guidance for entities considering using facial recognition technology (FRT) in high-volume, publicly accessible physical spaces, like retail shopfronts.

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EU Digital Omnibus on AI Enters Into Force

By: Sarah Pearce and Thomas Nietsch

The EU has adopted its first substantive amendment to the AI Act. Regulation (EU) 2026/1744, commonly referred to as the AI Omnibus, was published in the Official Journal on 24 July 2026 and entered into force on 27 July 2026. While the legislation postpones certain aspects of the AI Act’s compliance timetable, it would be a mistake for organisations to view the Omnibus as a broad pause on AI regulation in Europe.

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Washington State Enacts First-of-Its-Kind Chatbot Disclosure Law

By: Nicole H. Buckley and Whitney E. McCollum

Washington State Governor Bob Ferguson recently signed House Bill 2225 (the Chatbot Disclosure Act) into law, effective 1 January 2027. The Chatbot Disclosure Act requires people and entities who operate AI “companion” chatbots to provide clear and ongoing disclosure to Washington consumers that they are interacting with an automated system and not a human being.

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Mixed Blessings: Decision on Appeal by Bunnings Against Privacy Commissioner’s Determination Re the Use of Facial Recognition Technology

By: Cameron Abbott and Rob Pulham

The Administrative Review Tribunal of Australia (Tribunal) has partially overturned the findings of the Privacy Commissioner on Bunnings’ use of facial recognition technology (FRT) in its stores.

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AI Models May Be Trained With Publicly Available Data From Social Networks, Says the Higher Regional Court of Cologne (Decision of 23 May 2025, Ref. 15 Ukl. 2/25)

By: Dr. Thomas Nietsch and Andreas Müller

In proceedings initiated by a Consumer Protection Agency for a preliminary injunction against the operator of a social network to prohibit the use of publicly accessible user data for AI training, the competent court ruled that using such data is permissible under the General Data Protection Regulation (GDPR.)

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Termination Button–Also Required for Agreements With Automatic Expiry and One-Time Payment

By: Dr. Thomas Nietsch and Andreas Müller

In a recent ruling (I ZR 161/24, 22 May 2025), the German Federal Court of Justice (BGH) clarified the scope of § 312k German Civil Code (BGB) regarding the obligation to provide a ‘cancellation button’ on websites if traders enable consumers to conclude continuing performance contracts (Dauerschuldverhältnis) via their website.

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Deployment of AI in the Workplace in France–The Importance of Consulting With the Work Forces

By: Claude-Étienne Armingaud

In a significant ruling on 14 February 2025, the First Instance Court of Nanterre, France ordered a company to suspend the deployment of several artificial intelligence tools until proper consultation with its Works Council has been completed.

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