Serious Privacy

Big Developments this week - with Ralph O'Brien

May 31, 2023 Dr. k royal and Ralph O'Brien Season 4 Episode 19
Serious Privacy
Big Developments this week - with Ralph O'Brien
Show Notes Transcript

In this episode of Serious Privacy, Dr. K Royal joins with co-host Ralph O’Brien, while Paul Brietbarth of Catawiki is off conferencing, to discuss recent developments in privacy. Tune in to catch us discuss the Meta penalty from the Irish Data Protection Commission, the IAB Trust and Consent Framework 2.0 (in its continuing saga with the Belgian DPA), and concepts of controller and processor. Some resources we discuss are the Meta news release, noyb’s news release on Meta’s penalty.

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[Transcription provided via technology which may not reflect our words. For accuracy, please refer to the audio.]

[00:00:00] k: Hello and welcome to Serious Privacy. This week Paul is actually off at the conference doing conference things and so we have asked our delightful informal co-host. We should actually make him pretty formal cuz he, he's basically the only co-host we use cuz we like him. I've asked Ralph O'Brien to come join us for the show.

Now the funny thing is Ralph is at the same conference that Paul is, but.

[00:00:37] Ralph: Paul is much more important than I am. He's, his diary is booked out. he actually put on LinkedIn. There are luxury horses and there are work horses, and Paul is the luxury horse.

[00:00:47] k: Oh, there you go. So we've invited the workhorse to the podcast, and the good thing is we have plenty of privacy stuff to talk about this week, rather than last week was the kitchen sink and all the extra things to catch up. We actually have some pretty cool developments this week. So my name is Kay Royal.

[00:01:05] Ralph: My name is Ralph O'Brien and welcome to Sirius Privacy.

[00:01:09] k: Ralph, what if I let you ask the unexpected question? Do you have one?

[00:01:14] Ralph: Well, an unexpected question. Well, funnily enough I was just I was just talking about food. We were just talk, just having a wonderful conversation about food. Just well left with Paul Jordan who used to be the managing director of Europe for I B

[00:01:28] k: Yeah.

[00:01:29] Ralph: And, and, and Paul was talking about his, his preference for a massive Irish full English breakfast or that's a bit of a contradiction in terms.

So there you go. Breakfast light or heavy.

[00:01:42] k: I'm gonna say light. My husband brings me breakfast in bed every day and has done so for going on 22 years unless I'm not here, of course. But right now my breakfast is pretty healthy. It typically consists of scrambled eggs and blackberries. This morning I had bacon and blackberries, so I guess that's considered pretty light.

[00:02:03] Ralph: Oh, it's beautiful. It's beautiful. Yeah. I, I'm a, I'm a perhaps understandable from English and Irish heritage. I'm a full English person myself, so I like to fill up and be full for the rest of the day. And asleep by, by Midmorning, right.

[00:02:16] k: Yes, yes. That, that just basically takes care of the whole day. You can just snack for the rest of the day, right?

Yeah. I'm trying to lose these extra covid pounds that, you know, the whole world has gained mainly, most people, I think, have tried to work theirs off. Mine ain't happening. I'm trying, I'm trying.

People, I'm trying. But here we go. And the only problem it really bothers me is one, it impacts my health. Cuz you know, we don't want diabetes and all that stuff, but two, I have so many cute clothes that don't fit anymore and I don't want to go buy a whole new wardrobe. So, okay, here we go. Let's actually talk about some privacy stuff.

Like say we got significant things. I think yours are a little bit more momentous than mine are. So let me throw mine out there really quick. This is really quick. Tennessee actually did sign their privacy bill into law. It was on May 11th, so just last week or two ago. So we have that. Montana and Texas have not signed yet, and to my knowledge, we have not had another one pass yet.

I'm looking quickly. I don't see another one that has passed yet. Let, let's give another shout out to I A P P for their state legislation tracker, cuz we absolutely love it. And I will say that that's about it for the US that that's really momentous right now. We have a few other things that have really happened momentously in Europe.

And what would you like to start? I was about to say, Paul, what would you like to start with? Ralph

[00:03:45] Ralph: So, yeah. I mean, but in a way is, isn't that beautiful actually, that you've gotta check day by day in the US to see a new development? Isn't that, isn't that, what would we have seen that a year ago? I just think that's amazing, right?

[00:03:55] k: No, no, it is. We've got 10. We're up to 10. I think that if not that, if Pastor signed, I think we're up to eight that have signed and go into effect. Not to mention the Washington My Health, my Data app, which will go into most effect in 2024. For most of their provisions, and so that one's to wait on.

But yeah, it's, it's pretty cool watching things move and groove in the US when it comes to privacy, especially once we're not doing the one that really, really matters, the federal privacy 


[00:04:27] Ralph: federal premise in law.

[00:04:28] k: And there's no guarantee that just because states pass it, that the federal will, because we, every state has their own data. Privacy breach notification law, but the federal yet has to pass one. So there's no guarantee that just because there'll be 50 different privacy laws that the federal will.

However, I think the differences in the privacy laws are a little bit more significant than the breach notification laws.

[00:04:50] Ralph: They are. And you know, while you are dealing with 50 different privacy laws you know, we are still dealing with the fallout of our one. So the biggest news from Europe this week of course is the D P c decision on meta

that most people listening to this will know, resulted in a 1.2 million euro that is a 1.3 sorry, 1.2 billion

[00:05:14] k: Yes. I was gonna say 

[00:05:15] Ralph: fine. Yeah. Yeah. And what, or 1.3 billion dollar. In US money penalty and perhaps more important than that six months to suspend their transfers and delete the data that has been transferred

[00:05:28] k: Now, did they order the data to be deleted? Because I think I read something that there was no order for the data to be deleted. They just had to bring their transfer mechanisms into alignment.

[00:05:39] Ralph: well, it's difficult to bring them into alignment. When there's almost no option left for them to align to,

[00:05:47] k: the thingy, we have the thingy, right? We're, we're all basing our hopes on the thingy. The e u s cross Border Privacy transfer framework, something thingy.

[00:05:58] Ralph: I, I, I think it's worth saying it's not a good look for the D P C because. It's actually the European Data Protection Board, of course, that has forced the DPCs hand in this. And even though the judgment officially comes from the dpc, it's obvious in Ireland, who others as the lead regulator. It's obviously the European Data Protection Board making the making the assessment with, with the rest of the privacy regulators of Europe against Meta.

Now, now you are quite right, the thingy. Because Meta's response, you know, Nick Clegg, the old UK deputy Prime Minister now Facebook Head of Communications, has put out a really interesting response or rebuttal perhaps. 

And it seems to me, based on five points, I mean, their first point was service will continue and we will appeal. Fair enough. Number two, the second point was basically if everyone else is doing it, why can't we like, you know, it's a bit like we are the victims here. You know, you know, because, you know, Google's doing it, China's doing it.

Why focus on the us? You know? And I, to, to be fair, I kind of sympathize with a tiny bit. 

as the, as 

[00:07:05] k: bit, 

[00:07:06] Ralph: the As. Yeah. Yeah. I mean, hey, you

know, , it's. Yeah. The, their next point was, it's US surveillance at fault, not us. You know, you know, we are being penalized for something that's essentially an EU versus US policy problem, regardless of

the fact we are transferring the data, which I think is an interesting sort of 


[00:07:26] k: interesting. Yeah 

[00:07:27] Ralph: and the next point is the new executive. All the Solve Us. All right? Except for the fact 

[00:07:33] k: everything.

[00:07:34] Ralph: except for the fact it doesn't. You know, I, I've just come from the, the C P DP Conference here in Brussels, where we've just been privileged enough to listen to commission Didier Re Reys, and you know, he, he, he said, look, We're not there yet.

You know we we're implementing this, this new decision, the US plans to implement this new court and the new necessity and proportionality hopefully by November. And it's only then, and then we can start to think about a new adequacy or, or, or your, or equivalent international agreement for the us.

So we are in this sort of weird gap space at the moment where,

 It's a really interesting situation. And, and I, I think their, their last point, their fifth point was basically how dare the E D P B overall, the D P C, who are always nice to us. It's, you know, what sort of administration are we dealing with here where Europe can overrule the, the, you know, the you know, the local regulator.

And I think

[00:08:30] k: isn't that 

[00:08:31] Ralph: interesting point as well. 

[00:08:32] k: from the I G P C?

[00:08:34] Ralph: Well, exactly. Yeah. And it's not a good look for the, for the Irish DP C when they're taking a court case out against Europe 

basically help meta out . You know, it's a very interesting situation where you've got the DPC advocating almost on behalf of tech company against the European colleagues.

I mean, you know, politically, what a bizarre situation

[00:08:54] k: Yeah. I mean, you'd 

[00:08:56] Ralph: yeah. 

[00:08:56] k: that, you know, in the US

[00:08:59] Ralph: Right. Yeah, of course. So that's the first big, big piece of news. I mean, realistically, I think with these large tech firms, there's always a bit of bait and switch going on. And what I mean by that is, you know, it's like when we find a judgment against, you know, you can't use contract.

For, for, you know, well, we'll switch it to legitimate interest

then, or, or, you know, and, or we not getting valid consent. Well, well, we'll do this then. Oh, well you can't use SCCs. Well, okay, we'll switch to this, the executive order then, you know, and, and, and there seems to be like for every judgment we bring out, and these judgements take a long time.

Of course

But it is huge. I mean, I mean, let's face it, we are looking here at you know, 1.3 billion, which I know, you know, in Facebook terms. I, I actually did, did the math earlier


[00:09:43] k: go do the math for us? I became a lawyer so I didn't have to do the math, but

[00:09:46] Ralph: Yeah, it was, it was it was North Point, sorry. It was 1.4% of their last year's global annual turnover. There you go.

[00:09:55] k: that's not shabby. 

[00:09:57] Ralph: Yeah, 1.4% of their global annual turnover there,

[00:10:00] k: Do you think they'll ever go up to a 4%?

[00:10:03] Ralph: I don't know. I mean, you know, that's 

gonna represent. 

[00:10:05] k: earth shattering.

[00:10:07] Ralph: They've got to represent, that's gotta represent the worst privacy thing in the world, ever.

Right? And you know, so their turnover was 160 billion. We're looking here at, you know, 1.3 billion in response to that. So it's just over 1%. You know, really, really sort of fascinating. But as, as the wise man once said, if you earn more money by parking your car illegally than the, than the fine ticket, you've gotta keep parking your car illegally.

[00:10:33] k: Yeah, exactly. 

Exa you take that as the cost of doing business and if it's worth the risk and the profit works, then yeah, it's the return on investment.

[00:10:45] Ralph: So, you know, even though the headline sounds great, I think we're looking at a long road yet with appeals, they've got a, they've got a six month stay before they actually have to implement things, you know, and anything could change in that next six months, 

[00:10:59] k: Yeah. 

[00:11:01] Ralph: the safeguards under the new executive order.

[00:11:04] k: Yeah. The, the thingy may actually work. So it reminds me with you talking about six months six months in appeals makes me think of the a, b and the T C F.

[00:11:15] Ralph: Yep. So as it's a shame Paul isn't here, cuz of course he loves to talk about the Belgian author's


[00:11:21] k: legitimate interest for cookies, right? That's 

[00:11:23] Ralph: he does. 

[00:11:24] k: jam,

[00:11:26] Ralph: He does. And, and as we know, the Belgians found against the IAB Europe and, and, and said that their TCF transparency and consent framework is neither transparent nor based on consent essentially.

And so they've responded, they've responded, they've brought out what they now call TCF 2.2 on the 16th of May 2023. And that does a number of different things, one of which is removing the ability of the TCF vendors to rely on legitimate 

interests for advertising and, and content personalization, which they call and, and allow only consent as an acceptable legal basis for what they call purposes three, four, five, and six at registration level Now.

It's an improvement. There's no getting away from the fact that's an improvement. We are getting rid of legitimate interests for purposes 3, 4, 5, and six. But that leaves purposes 1, 2, 7, 8, 9, 10,

[00:12:23] k: Right, 

[00:12:23] Ralph: 13, 14,

[00:12:24] k: right. Well, And they have two appeals right now, right? They have one in Belgium to the Belgian market court, and then they have an appeal to the C, the Court of Justice, of the European Union, C J E U, which does not roll off the tongue easily. And what they're appealing on is the foundation. Of the decision, which found that they are a joint controller because they do determine the purposes and the actions of the data.

And two was what is the you'll have to remind me on the second one, is it whether or not the TC string qualifies as personal data, which I think they're gonna lose that one. Because their argument is that it's not unique. Well, neither is an address. You can have 15 people living at the same address and that doesn't matter.

It's ip. 


So that part they're gonna fail on. But what do you think about the part of them being a code controller?

[00:13:16] Ralph: Yeah. I think that was the most interesting one.

You know, 

[00:13:19] k: in trouble for so much of the 

[00:13:20] Ralph: Yeah, I mean, you know, they have come up with the they've come up with the standard and you know, the consenting does go back to the, go back to them. So you, are they determining means and purposes? The Belgian DPA says yes. They say no. I think it's, that's gotta be one for the courts.

[00:13:38] k: But don't they have kind of a, it's not a real certification process, but don't, don't they have like a process where they verify that the company is using the TCF correctly and adhering to their rules, and if they're making an independent decision, that might go against the controller. That's a co controller, because otherwise the controller would say, yes, we are using it.

Right? And they would say, oh yeah, we're wrong. We're sorry. You are using it. Right. If they were a 


[00:14:06] Ralph: I mean, I, I, I'm not sure whether I necessarily fallen along the lines of joint controllers, but, but certainly a controller in their own rights. Yes. You know, because they're, they're 

they're determining their own means and purposes, right? They're, they're, they're determining their own means and purposes, whether joint or not, I think is a, is another question, but I, but I think they're using it for their own means and purposes, which under law would make them a controller.

[00:14:26] k: Yeah. And there is a, there is a difference between a joint controller and a co controller or a controller in common. I think the UK has a, a definition and maybe joint and code the same thing, and a controller in common is a little different.

[00:14:40] Ralph: Yeah.

[00:14:41] k: nuances that only privacy geeks get into.


[00:14:45] Ralph: Yeah, I mean, you know, controllers in common, well, we don't really use the term anymore. It's a bit of an antiquated term, but Yeah. It means more than one controller in a data flow. Yeah. Yeah. More than one controller in a data flow. So you know, you could, you could be an employer passing data to a pensions provider.

You both be separate controllers because you've got separate legal relationships with the individual, but because you're passing data to each other as well. This is whole controllers in common was sort of a, a UK legal term we banded around for a long time, and that's very different from a joint controller, of course, which are jointly determining

[00:15:14] k: I, I like the controller and common concept though. 

[00:15:18] Ralph: I've always said that like cloud providers, even though they say that they're processors, obviously, you know, they say sign out terms, conditions, and they're often more in control than the controller is, even though they say they're only a processor because, you know,

[00:15:31] k: and we hired them for their control, their

[00:15:34] Ralph: exactly.

[00:15:34] k: their ability to, to do with the data, things that we can't do. So I'm, I'm eager for this term.

[00:15:40] Ralph: So, so how, how's this for a definition if you've got a processor who's more in control of the data than you are, we should call them a controlling processor.

[00:15:48] k: Ooh, I was imagining you were gonna go control our processor, but controlling processor or processor in control. 

[00:15:56] Ralph: Yeah, exactly. You know, so I, I mean, hey, we're just blowing most people's minds, I'm sure are geeking out here, but you know, that's not a legal definition that exists. I wanna make that clear. 

[00:16:05] k: Is got the same legitimacy as the thingy

[00:16:08] Ralph: yeah, yeah. Totally. Yeah. But, but, but I think we do, we actually, you know I think the GDPR is a little bit outta date in using concepts like controller and processor with this

[00:16:17] k: Yeah.

[00:16:18] Ralph: that, that you as a controller can tell your processor what to do when often, sometimes it's the processor telling the controller what the law

is and what 

[00:16:24] k: Well, that's the whole thing. A lot of times we hire these processors

again because of their expertise and their capabilities.

[00:16:32] Ralph: As, as we all want to do, we've wandered off topic a little bit. The other thing I, the other thing I should say, just to bring us back to the TCF is, you know, The other big change with TCF 2.2 from the I B Europe. Is that vendors are gonna be required to be a little bit more transparent.

Provide additional information about, about the data processing operations, you know, what categories of data they're collecting, the retention periods. Purpose. Purpose, and not, not just say legitimate interests, but also. What that legitimate interest is. You know you have to remember that actually legitimate interest isn't really a legal basis.

You're supposed to say what your interest is and how it beats their, you know, essentially rights freedoms, right. 

So and that includes transparency over the number of vendors. The CMPs will be required to disclose 

[00:17:18] k: Which is gonna be interesting. They have to disclose the number of vendors who are trying to establish a legal basis for the first layer of the user interfaces.

[00:17:29] Ralph: Exactly. Yeah. And, and also when you are give consent, how to get out of it again you know, make sure that's very easily, easily done and easily withable, which again, 

I don't think Is a feature of today. 

[00:17:41] k: cause it's a common requirement, but who actually does it?

[00:17:46] Ralph: Yeah. I've always had a problem very much like Paul, and I'm sure Paul would, would fake me on this, that, you know, even if you are relying on legitimate interests for advertising, which I personally like Paul, don't believe you can do. Quite often what happens is you can click reject all. They say, great, we're still gonna do it under legitimate interests where you can go into the settings and click object.

I think my biggest problem isn't the fact they're using legitimate interests, but it's Well, if you click object, so what do you never get a notification back saying,


[00:18:15] k: Right, right. 

[00:18:15] Ralph: been upheld, or it hasn't. I suspect they go Right. Thank you. We register your objection and we're still gonna do it anyway.

you know?


[00:18:25] k: can hear Alexander Hamp. Just, just right.

[00:18:29] Ralph: Well, I'm gonna see Alex in the next couple of days. He's presenting here at C P

[00:18:34] k: That's right. That's right. Tell 

[00:18:35] Ralph: Yeah. 

Yeah. And in, in fact, I also met Barbara and Marty here

[00:18:41] k: nice. 

[00:18:42] Ralph: Who, who I came to know through doing this podcast. So it's been lovely to meet some people face to face

[00:18:48] k: Oh, that, is awesome. 

[00:18:49] Ralph: wouldn't have done.

So it's been a lovely event. 

[00:18:52] k: I was trying to get over there during this time and took a new job and so have had my time scraped up by otherwise. 

[00:18:59] Ralph: Isn't it amazing? And, and, you know, and, and again, you know, I hate to keep going back to the conference, but I mean, just the amount of people in, in, in, in, in this industry who you meet, and I mean, today I've spoke to our friend Marie Penot, Tim Clemens, Max Schrems, of course, Stuart Drek.

Simon Haier.

Paul Jordan, I mean, the names that are here at the moment. And, and, and I've gotta say it's a privilege to be working alongside such luminaries. I mean, 

[00:19:26] k: Yeah. 

[00:19:26] Ralph: just, just people in

[00:19:28] k: it, it really is. It really is.

[00:19:31] Ralph: It is, and, and you know, I mean, we were all stuck in for the pandemic for a couple of years, but to be back out there amongst, amongst the, the sort of people I've met today and the sort of ideas that are coming out and the sort of things that we are discussing, 

you know, It gives me hope. You know, I, I, I've often said we are fighting the rear guard of a losing action when it comes to data, right? That's, that, that's the way I've described my industry for a long, long time. We're fighting the, the rear guard of a losing action. But, you know, it's a, I've had, I'm actually for the first time, you know, come, come across here and we're from a thoroughly depressing situation in the UK. Find, you know, finding, you know, a degree of hope amongst my European colleagues.


[00:20:09] k: That is, that is nice to hear. And it's really nice to see all the developments globally. I think I saw something the other day. There are 137 countries out of 194. Now, the way you count the number of countries is very varied, but on this report, I think it was from the UN 137 out of 194 now have privacy laws and essentially omnibus privacy laws, 

[00:20:32] Ralph: Yeah, of course. 

[00:20:33] k: And so it's really, it's heartening, isn't it? 


[00:20:37] Ralph: it? 

is, It is, heartening.

You know, you know, my, my skepticism kicks in with, you know, we, there, there is be a level of enforcement that, that perhaps we, we struggle with, certainly in, in some way, even here in Europe. You know, there's enforcement issues with people like the G P C and the I C O,

but you know, in, you know, when you are first starting up a new regulator, you know, let's say in, in, you know, in, in, in, in, in some of the countries in Africa or in South America or in Asia, you know getting those first enforcement actions out the door, getting 

[00:21:07] k: Yeah. 

[00:21:08] Ralph: to listen to you know can often be the trouble and the trick.

Right. You

[00:21:12] k: Well, and you learned from what other countries are doing. So you're watching what, I mean, you're not just watching just what happens in Europe or just what happens in the UK or just what happens in China, or just what happens in the US or Canada. You're, you're watching what's happening in a lot of countries that are making interesting moves in what they're choosing to do.

[00:21:34] Ralph: Well you know, in a few weeks time, we're gonna have the Global Privacy assembly again in 

Bermuda. Which, 

[00:21:39] k: I won't be going to that 


[00:21:41] Ralph: Yeah, Yeah, I, I'm, I'm gutted. I won't be there either. And I, I, I think Paul's going typically 

[00:21:46] k: he,

[00:21:47] Ralph: the, the, luxury horse. Yeah.

[00:21:49] k: Ralph, you and I get to say we know Paul.

[00:21:52] Ralph: Exactly. Yeah. So you know, he's and on that point, actually, I should probably say congratulations to him because

he, he took up posts for the work he's doing with . With, with the Jersey commissioner as well. I understand. He had a very productive first meeting in in Jersey over the last

weekend as well.

So, so you know so, you know, I managed to pass on Michael, my congratulations to him face to face and, you know, I, I hope with the commissioner out there, Paul vain, they continue to do great work down there in Jersey. So you know, and, and, and I think people forget, you know, when we talk about 137 countries, you know, it's not just the Americas and the Chinas and the, and the Europes of this world, you know you know, you've had people like Emma Martin on the podcast 

[00:22:32] k: Yep. 

[00:22:32] Ralph: and, and you know, the work that they're doing down in the Channel Islands and, and in, in some of the, I hate to say it, the you know smaller in 

terms of the number of people,

[00:22:40] k: Well, they're smaller, let's be frank. They are smaller. Are they? They're some, A lot of them about the same size as the states that we 

have here. And that's huge. 

[00:22:49] Ralph: but things like Emma and Paul, that, that, you know, the, the, the commissioners in those smaller areas, they're still doing great, great 


[00:22:55] k: Yeah. 

[00:22:55] Ralph: Emma's Project BG, for example, is just


[00:22:58] k: yeah. Right. Absolutely. Amazing. So I agree with you. It's really, we're in, I hate to say it, but I'm gonna do it. We're in a transformational time. We're actually seeing the moving and the grooving now. True. To be honest, you go outside the privacy network and most people have no clue that Texas just signed a law.

I get that. 

[00:23:18] Ralph: to you to use another comment. We're all on a journey.

We're all on a journey, Kay? Yeah. 

[00:23:24] k: Some of us are in a wagon, some of us 

[00:23:26] Ralph: Yeah. Yeah. And. 

[00:23:29] k: We're all on the same path.

[00:23:30] Ralph: And, and, and I, and I do think it's really interesting actually that, that we are still seeing some really interesting topics while we're seeing new topics pop up over here. Like AI is obviously dominating the agenda 

at this conference that I'm at the moment. But eek, we were seeing old favorites pop up.

It. Pricy and programmatic advertising

or, and you know you know, so, so, you know, we're still seeing an international transfer, so it's, there's still some old favorites there, but equally we're seeing some of the new technology stuff kicking in. And what I'm really pleased about seeing on the agenda is a lot more work about privacy by design, 

being more proactive, not looking at data protection as a legal cost,

but looking 

[00:24:07] k: Right, 

[00:24:08] Ralph: as a pro, as a proactive, functional benefit.


[00:24:10] k: Oh, absolutely. Absolutely. You don't 

[00:24:13] Ralph: and. 

[00:24:13] k: work for a privacy company. To be able to see that privacy is something that's added value to the company for the expertise that we bring.

[00:24:24] Ralph: Yeah, exactly. So I know kay. We always want to keep these, you know, fairly short to make sure the listeners can make sure that they

you know, we, we don't overstay aware. 

[00:24:33] k: minutes.

[00:24:34] Ralph: We don't overstay our welcome. I was gonna say but I do want, before we go today, just j just finish off with a wonderful quote from commissioner Didier res today.

You know, he, he's talked about obviously the, the EU u s privacy shield aside privacy shield in invalidation and its replacement by the executive order. And his, his last sentence will perhaps go with me for, for, for quite some time. And it, and it was simply this, we know. With the new executive order, we will have a Schrems free, but this time we hope the commission and our US colleagues will win the final decision. which I thought was an optimistic outcome for the European Commission and their US colleagues.


[00:25:19] k: his mouth to God's ears, or more importantly, to Max Schrems

[00:25:24] Ralph: But I thought time will tell. And I thought that was a wonderful way to finish his to, to, to, to finish his moment in the spotlight and his

[00:25:31] k: That is awesome. That's perfect. Well, Ralph, thank you once again for finding us. I do have to add our. Our standard closing, which I don't have open in front of us, and I'm usually making faces at Paul while he's reading it. If you ever hear 'em break while he is talking, but thank you. Thank you. To our listeners, please find us.

Listen to us on your favorite podcast application. like us, make remarks, make a rating on us. The more you do that, the more other people can find us and can benefit from the wonderful wisdom that we bring to the privacy field.

[00:26:03] Ralph: And accommodate value

[00:26:05] k: Exactly. Exactly. You can find Paul on social media at Euro Paul B on Twitter.

You can find him on LinkedIn. You can find the podcast on LinkedIn under Serious Privacy. Please do join us there, ask questions, get involved. You can find Ralph on Twitter as. 

[00:26:21] Ralph: at I G R O'Brien. AT I G R O'Brien.

[00:26:25] k: and you can find me as heart of privacy. So thank you so much for joining us. We look forward to connecting with you again, Ralph. Love having you. 

So Paul usually says, until next time, goodbye.

[00:26:38] Ralph: Until next time. 


[00:26:40] k: Bye y'all.

[00:26:42] Ralph: Bye.