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Stacy Young

Stacy Young is an associate in the London office. She advises technology and life sciences companies across a range of privacy and regulatory issues spanning AI, clinical trials, data protection and cybersecurity.

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On June 5, 2025, the UK’s Information Commissioner’s Office (“ICO”) launched its new AI and biometrics strategy. The strategy aims to increase its scrutiny of AI and biometric technologies focusing on three priority situations, namely where: stakes are high; there is clear public concern for the technology; and regulatory clarity can provide immediate impact.

The ICO identified three areas of focus in its strategy:

  1. Transparency and explainability, i.e., when and how the technologies affect people;
  2. Bias and discrimination, particularly where the technologies have been trained on “flawed, incomplete or unrepresentative information”; and
  3. Rights and redress, i.e., making sure that systems are accurate, appropriate safeguards are in place to protect people’s rights, and that there are ways to challenge and correct outcomes that result in harm.

Continue Reading The ICO’s AI and biometrics strategy

On June 2, 2025, the Global Cross-Border Privacy Rules (“CBPR”) Forum officially launched the Global CBPR and Privacy Recognition for Processors (“PRP”) certifications.  Building on the existing Asia-Pacific Economic Cooperation (“APEC”) CBPR framework, the Global CBPR and PRP systems aim to extend privacy certifications beyond the APEC region.  They will allow controllers and processors to voluntarily undergo certification for their privacy and data governance measures under a framework that is recognized by many data protection authorities around the world.  The Global CBPR and PRP certifications are also expected to be recognized in multiple jurisdictions as a legitimizing mechanism for cross-border data transfers.Continue Reading Global CBPR and PRP Certifications Launched: A New International Data Transfer Mechanism

On November 6, 2024, the UK Information Commissioner’s Office (ICO) released its AI Tools in recruitment audit outcomes report (“Report”). This Report documents the ICO’s findings from a series of consensual audit engagements conducted with AI tool developers and providers. The goal of this process was to assess compliance with data protection law, identify any risks or room for improvement, and provide recommendations for AI providers and recruiters. The audits ran across sourcing, screening, and selection processes in recruitment, but did not include AI tools used to process biometric data, or generative AI. This work follows the publication of the Responsible AI in Recruitment guide by the Department for Science, Innovation, and Technology (DSIT) in March 2024.Continue Reading ICO Audit on AI Recruitment Tools

On July 30, 2024, the European Commission announced the launch of a consultation on trustworthy general-purpose artificial intelligence (“GPAI”) models and an invitation to stakeholders to express their interest in participating in the drawing up of the first GPAI Code of Practice (the “Code”) under the newly passed EU AI Act (see our previous blog here). Once finalized, GPAI model providers will be able to voluntarily rely on the Code to demonstrate their compliance with certain obligations in the AI Act.Continue Reading European Commission Launches Consultation and Call for Expression of Interest on GPAI Code of Practice

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 3, 2024, the UK Information Commissioner’s Office (“ICO”) published its 2024-2025 Children’s code strategy (the “Strategy”), which sets out its priorities for protecting children’s personal information online. This builds on the Children’s code of practice (“Children’s Code”) which the ICO introduced in 2021 to ensure that all online services which process children’s data are designed in a manner that is safe for children.Continue Reading ICO sets outs 2024-2025 priorities to protect children online

On December 5, 2023, the Spanish presidency of the Council of the EU issued a declaration to strengthen collaboration with Member States and the European Commission to develop a leading quantum technology ecosystem in Europe.

The declaration acknowledges the revolutionary potential of quantum computing, which uses quantum mechanics principles and quantum bits known as “qubits” to solve complex mathematical problems exponentially faster than classical computers.

The declaration was launched with eight Member State signatories (Denmark, Finland, Germany, Greece, Hungary, Italy, Slovenia, and Sweden), and invites other Member States to sign. By doing so, they agree to recognize the “strategic importance of quantum technologies for the scientific and industrial competitiveness of the EU” and commit to collaborating to make Europe the “’quantum valley’ of the world, the leading region globally for quantum excellence and innovation.”Continue Reading Quantum Computing: Action in the EU and Potential Impacts

On July 7, 2023, the UK House of Lords’ Communications and Digital Committee (the “Committee”) announced an inquiry into Large Language Models (“LLMs”), a type of generative AI used for a wide range of purposes, including producing text, code and translations.  According to the Committee, they have launched the inquiry to understand “what needs to happen over the next 1–3 years to ensure the UK can respond to the opportunities and risks posed by large language models.”

This inquiry is the first UK Parliament initiative to evaluate the UK Government’s “pro-innovation” approach to AI regulation, which empowers regulators to oversee AI within their respective sectors (as discussed in our blog here).  UK regulators have begun implementing the approach already.  For, example, the Information Commissioner’s Office has recently issued guidance on AI and data protection and generative AI tools that process personal data (see our blogs here and here for more details). Continue Reading UK House of Lords Announces Inquiry into Large Language Models

On February 11, 2021, the European Commission launched a public consultation on its initiative to fight child sexual abuse online (the “Initiative”), which aims to impose obligations on online service providers to detect child sexual abuse online and to report it to public authorities. The consultation is part of the data collection activities announced in the Initiative’s inception impact assessment issued in December last year. The consultation runs until April 15, 2021, and the Commission intends to propose the necessary legislation by the end of the second quarter of 2021.
Continue Reading European Commission Launches Consultation on Initiative to Fight Child Sexual Abuse

On December 15, 2020, the European Commission published its proposed Regulation on a Single Market for Digital Services, more commonly known as the Digital Services Act (“DSA Proposal”).  In publishing the Proposal, the Commission noted that its goal was to protect consumers and their fundamental rights online, establish an accountability framework for online services, and foster innovation, growth and competitiveness in the single market.  On the same day, the Commission also published its proposal for a Digital Markets Act (“DMA”), which would impose new obligations and restrictions on online services that act as “designated gatekeepers” (see our analysis of the DMA Proposal here).
Continue Reading EU Publishes Proposal For Digital Services Act