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Paul Maynard

Paul Maynard is special counsel in the technology regulatory group in the London office. He focuses on advising clients on all aspects of UK and European privacy and cybersecurity law relating to complex and innovative technologies such as adtech, cloud computing and online platforms. He also advises clients on how to respond to law enforcement demands, particularly where such demands are made across borders.

Paul advises emerging and established companies in various sectors, including online retail, software and education technology. His practice covers advice on new legislative proposals, for example on e-privacy and cross-border law enforcement access to data; advice on existing but rapidly-changing rules, such the GDPR and cross-border data transfer rules; and on regulatory investigations in cases of alleged non-compliance, including in relation to online advertising and cybersecurity.

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As the UK Government has recognized, cyber incidents—such as Jaguar Land Rover, Marks and Spencer, Royal Mail and the British Library—are costing UK businesses billions annually and causing severe disruption. The Government recognizes that cybersecurity is a critical enabler of economic growth (“we cannot have growth without stability”), and that the current laws have “fallen out of date and are insufficient to tackle the cyber threats faced by the UK.” Accordingly the UK Government this week published its long-awaited Cyber Security and Resilience Bill (the “Bill”), which will amend the existing Network and Information Systems Regulations 2018 (the “NIS Regulations”), and grant new powers to regulators and the Government in relation to cybersecurity.

The NIS Regulations are the UK’s pre-Brexit implementation of Directive (EU) 2016/1148 (the “NIS Directive”), which established a “horizontal” cybersecurity regulatory framework covering essential services in five sectors (transport, energy, drinking water, health, and digital infrastructure) and some digital services (online marketplaces, online search engines, and cloud computing services). EU legislators replaced NIS Directive in 2022 with the “NIS2” Directive, which Member States were meant to transpose into national law by October of last year (although many are still late in doing so. See our post on NIS2 here for an overview of the requirements of NIS2).

The Bill is the UK’s effort at modernizing the framework originally set out in the NIS Directive. In its current form, the Bill will:

  • Significantly expand the scope of the NIS Regulations—to cover, among other things, data centers and managed service providers—and impose additional substantive obligations on covered organizations.
  • Increase potential fines—up to GBP 17m or 4% of the worldwide turnover of an undertaking—and extend the powers of competent authorities to share information with one another, issue guidance, and take enforcement action.
  • Establish a framework for future changes to the NIS Regulations, mechanisms for competent authorities to impose specific cybersecurity requirements on covered organizations, and greater Government direction of cybersecurity matters.

Below, we set out further detail on five major changes in UK cybersecurity regulation arising from the Bill.Continue Reading Five major changes to the regulation of cybersecurity in the UK under the Cyber Security and Resilience Bill

Before issuing a proposal for a Quantum Act, the European Commission has issued a call for evidence (“Call for Evidence”), asking for views from all stakeholders on the best approach to addressing structural problems that the Commission has identified in the areas of research, industrial capacity, and supply chain resilience. Industry stakeholders already grappling with multiple EU data and cyber-related laws, regulations, and assessment procedures may be most interested in the proposal to develop an EU-level monitoring and resilience framework for supply chain products needed to build quantum technologies. The Call for Evidence is open until 26 November 2025Continue Reading European Commission launches a call for evidence on the impact assessment for the forthcoming EU Quantum Act

The EU e-evidence Regulation and Directive, which establish a regime for law enforcement authorities (“LEAs”) in one Member State to issue legally-binding demands for data from certain types of providers established in other Member States, will come into effect on 18 August 2026 (our post on the specific requirements of the Regulation and Directive is available here). On 28 July 2025, the European Commission adopted an Implementing Regulation (“IR”) setting out the technical specifications for the decentralized communications system that LEAs and covered service providers must use when, among other things, issuing and responding to European Production Orders (“EPOs”) and European Preservation Orders (“EPrOs”) under the e-evidence Regulation.Continue Reading European Commission adopts technical standards for the decentralized communication system to be used under the forthcoming e-evidence Regulation

On 25 June 2025, the European Commission (“EC”) announced its long-awaited proposal for a Regulation on the safety, resilience, and sustainability of space activities in the EU (the “Draft EU Space Act” or “Draft EUSA”). The Draft EUSA proposes to impose obligations on providers of “space services,” which are:

  • The operation and control of human-made objects sent to space;
  • The provision of space launch services;
  • Services provided by “primary providers of space-based data,” a term covering providers that carry out the first processing of either communications data or observation data received from outer space (which may include electronic communications service providers);
  • In-space services and operations; and
  • Collision-avoidance services.

Most of the obligations in the Draft EUSA would apply to providers of space services that are located in the EU, and those located outside the EU but that provide services to space operators in the EU. However, the rules on safety described below would apply to space objects that generate data or enable the provision of space services in the EU. These rules, and certain rules on collision avoidance, would also apply to space objects that at or lower than a geostationary orbit.

The explanatory memorandum notes that 13 EU Member States have passed national legislation related to space, which creates the risk of a fragmented internal market for the space sector. The Draft EUSA therefore establishes rules in four main areas in an attempt to harmonize the law relating to this sector, namely authorization and registration requirements, and obligations to ensure safety, resilience, and sustainability of space services. We describe these in more detail below.Continue Reading The European Commission announces a proposal for the first EU Space Act

On 24 June 2025, the European Commission published its “roadmap” for ensuring lawful and effective access to data by law enforcement (“Roadmap”). The Roadmap forms a key part of the Commission’s internal security strategy, which was announced in April, and follows on from the November 2024 recommendations of the High-Level Group on Access to Data for Effective Law Enforcement.

Of most immediate relevance to electronic communications service (“ECS”) providers, the Commission intends to propose new data retention requirements, is considering changes to better enable cross-border live interception of communications, and will support the development of tools enabling law enforcement authorities (“LEAs”) to access encrypted data. We describe these proposals, and other elements of the Roadmap, in more detail below.Continue Reading European Commission publishes its plan to enable more effective law enforcement access to data

The UK Information Commissioner’s Office (“ICO”) recently announced a new online tracking strategy, which aims to ensure a “fair and transparent online world where people are given meaningful control over how they are tracked online.”

Online advertising is one of the ICO’s current areas of strategic focus (others areas of focus include AI and children’s privacy). The ICO has identified four key areas of concern—all of which the ICO states mean that individuals do not have sufficient control over their personal data:

  • “deceptive or absent choice” regarding non-essential cookies and tracking technologies;
  • “uninformed choice,” which refers to organizations not providing appropriate information to individuals;
  • “undermined choice,” where individuals’ choices are not respected and they are surprised about how their data is used; and
  •  “irrevocable choice,” meaning that individuals cannot effectively change their minds after they have made a choice over how their personal data is processed.

Having identified these areas of concern, the ICO states that it will take the following actions in 2025:Continue Reading ICO announces its online tracking strategy for 2025

On 2 December 2024, the European Data Protection Board (“EDPB”) adopted its draft guidelines on Article 48 GDPR (the “Draft Guidelines”). The Draft Guidelines are intended to provide guidance on the GDPR requirements applicable to private companies in the EU that receive requests or binding demands for personal data from public…

Continue Reading EDPB adopts draft guidelines on requirements when responding to requests from non-EU public authorities

Last month, the European Commission published a draft Implementing Regulation (“IR”) under the EU’s revised Network and Information Systems Directive (“NIS2”). The draft IR applies to entities in the digital infrastructure sector, ICT service management and digital service providers (e.g., cloud computing providers, online marketplaces, and online social networks). It sets out further detail on (i) the specific cybersecurity risk-management measures those entities must implement; and (ii) when an incident affecting those entities is considered to be “significant”. Once finalized, it will apply from October 18, 2024.

Many companies may be taken aback by the granular nature of some of the technical measures listed and the criteria to determine if an incident is significant and reportable – especially coming so close to the October deadline for Member States to start applying their national transpositions of NIS2.

The IR is open for feedback via the Commission’s Have Your Say portal until July 25.Continue Reading NIS2: Commission Publishes Long-Awaited Draft Implementing Regulation On Technical And Methodological Requirements And Significant Incidents

On April 25, 2024, the UK’s Investigatory Powers (Amendment) Act 2024 (“IP(A)A”) received royal assent and became law.  This law makes the first substantive amendments to the existing Investigatory Powers Act 2016 (“IPA”) since it came into effect, and follows an independent review of the effectiveness of the IPA published in June 2023.Continue Reading Changes to the UK investigatory powers regime receive royal assent

On 6 March 2024, the ICO issued a call for views on so-called “Consent or pay” models, where a user of a service has the option to consent to processing of their data for one or more purposes (typically targeted advertising), or pay a (higher) fee to access the service without their data being processed for those purposes. This is sometimes referred to as “pay or okay”.

The ICO has provided an “initial view” of these models, stating that UK data protection law does not outright prohibit them. It also sets out factors to consider when implementing these models and welcomes the views of publishers, advertisers, intermediaries, civil society, academia and other interested stakeholders. The consultation is open until 17 April 2024.Continue Reading UK ICO launches a consultation on “Consent or Pay” business models