Author - Lianna Inthavong

1
Washington State Enacts First-of-Its-Kind Chatbot Disclosure Law
2
Mixed Blessings: Decision on Appeal by Bunnings Against Privacy Commissioner’s Determination Re the Use of Facial Recognition Technology
3
New Zealand Privacy Law Amendment Act Passes
4
UK Data Use and Access Bill Becomes Law
5
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
7
Deployment of AI in the Workplace in France–The Importance of Consulting With the Work Forces
8
New EDPB Guidelines: Processing Personal Data on Blockchain
9
Illinois Anti-Discrimination Law to Address AI Goes Into Effect on 1 January 2026
10
New EDPB Statement on Age Assurance: What You Need to Know

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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New EDPB Guidelines: Processing Personal Data on Blockchain

By: Claude-Étienne Armingaud

The European Data Protection Board recently published its draft Guidelines 02/2025, which remain open to consultation until 09 June 2025. Stakeholders in the blockchain industry are encouraged to submit any observations before the finalization of these Guidelines.

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Illinois Anti-Discrimination Law to Address AI Goes Into Effect on 1 January 2026

By: M. Claire Healy, Kathleen D. Parker, and Erinn L. Rigney

Effective 1 January 2026, Illinois House Bill 3773 (HB 3773) amends the Illinois Human Rights Act, (IHRA) to expressly prohibit employers from using artificial intelligence (AI) that “has the effect of subjecting employees to discrimination on the basis of protected classes.” Specifically, Illinois employers cannot use AI that has a discriminatory effect on employees, “[w]ith respect to recruitment, hiring, promotion, renewal of employment, selection for training or apprenticeship, discharge, discipline, tenure, or the terms, privileges, or conditions of employment.”

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New EDPB Statement on Age Assurance: What You Need to Know

By: Claude-Etienne Armingaud

On 11 February 2024, the European Data Protection Board (EDPB) adopted a new statement on age assurance. This statement, while not legally binding, will guide the enforcement of age-gating methods across the EU. Age assurance refers to the methods used to determine an individual’s age or age range with varying levels of confidence or certainty.

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