“Pay or consent” models under scrutiny

Pay or consent models are causing a stir both in the UK and the EU.

The ICO has launched a public consultation on the concept, which can be accessed here. The consultation closes on 17 April 2024. The responses to the consultation will help in the development of guidance in the area (the starting point of which the ICO lays out in the call for views).

Meanwhile, in Europe the Dutch, Norwegian and Hamburg data protection authorities have requested a binding opinion from the EDPB on the matter, which is expected shortly.

It will be interesting to see whether the approaches taken are similar or whether this might be another point of divergence between the UK and EU regimes.


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