Data Protection Monitor
Global Privacy & Data Protection Intelligence

JE Data Protection & Privacy Regulation

JE schema gdpri-v2 trajectory: not yet assessed regulated (omnibus) overlaps: Sentinel (AML/CFT), World Payments

Last updated · 10 categories · 51 claims · 22 sources in the cumulative register

The Jersey Office of the Information Commissioner launched its 2026-2028 Strategic Plan on 2 February 2026, built around three priorities — Children's Privacy, AI in HR, and Cyber Security — delivered through an Advise, Assess, Act enforcement model under which Commissioner Paul Vane stated that enforcement action will be taken without delay for clear non-compliance.

Data collected Data published

AI-assembled from cited sources

Not fully checked this cycle: Regulator & Framework, Data Subject Rights, Cross-Border & Adequacy, Algorithmic, Biometric & Surveillance Governance (4 open gaps).

Evidence re-verified: ·Position last changed: ·
Record history & provenance ▾

Methodology & record provenance: Module confidence is derived from the underlying claims (source tier and primary excerpt retention), while statutory legal force is tracked independently.

Review status: AI-synthesised · Tier-1/2 verified · As-of date: 2026-10-26

Framework postureRegulated (omnibus)10 of 10 modules populated · AI-synthesised · Tier-1/2 verified
Lead supervisory authorityJersey Office of the Information Commissioner (JOIC) / Jersey Data Protection AuthoriPrimary statutory & supervisory perimeter
Next milestone (> 2026-10-26)None scheduledNo dated future statutory milestone on record
Module coverage & confidence10 / 10 modules assessed0 Confirmed · 9 Probable · 1 Uncertain

Jurisdiction brief

Latest update · 25 October 2026

Lead Signal

The Jersey Office of the Information Commissioner launched its 2026-2028 Strategic Plan on 2 February 2026, built around three priorities — Children's Privacy, AI in HR, and Cyber Security — delivered through an Advise, Assess, Act enforcement model under which Commissioner Paul Vane stated that enforcement action will be taken without delay for clear non-compliance. The underlying Data Protection (Jersey) Law 2018 itself has not changed; what has changed is the supervisory posture applied to it, and that shift is corroborated by concrete enforcement activity: the JOIC issued decision notices against Infrastructure and Environment (25 June 2026), the Department for the Economy (13 May and 25 June 2026), and the Judicial Greffe (15 June 2026).

Key regulatory facts for JE
Regulatory DimensionJE Standing Position
JurisdictionJE (JE)
Regulatory ScopeData Protection & Privacy Regulation (10 modules, 51 sourced findings)
Regulator & FrameworkCore regulator identity, statutory basis and the UK/EU non-extension point are well evidenced at T1/T2; material-scope definitions and exact registration fee schedule were not retrieved from primary legislation in...
Lawful Processing & Special DataNo primary-instrument pinpoint located for lawful bases, consent thresholds or pseudonymisation tests; only one enforcement-derived special-category reference confirmed.
Data Subject RightsOne confirmed directional finding (shorter SAR window) at T3 confidence; remaining sub-modules unpopulated.
Controller/Processor DutiesBreach notification and security principle well evidenced; five of seven sub-modules unpopulated.
Primary Instruments CitedICO / JOIC, DataGuidance, EUR-Lex, JE Official Instrument (jerseyoic.org the-ink-dried-on-data-protection), JE Official Instrument (jerseychamber.com data-protection-registration-ren)
Last Confirmed / Updated2026-10-25 (22 sources in cumulative register)

#

Core regulator identity, statutory basis and the UK/EU non-extension point are well evidenced at T1/T2; material-scope definitions and exact registration fee schedule were not retrieved from primary legislation in this pass.

Primary frameworkData Protection (Jersey) Law 2018 / Data Protection Authority (Jersey) Law 2018
Traffic-light rationale — AmberCore regulator identity, statutory basis and the UK/EU non-extension point are well evidenced at T1/T2; material-scope definitions and exact registration fee schedule were not retrieved from primary legislation in this pass.

Sub-modules (5)

Regulator And AuthorityGreen

JOIC is the operating name of the JDPA, a statutory body under the DPAJL 2018 acting as Jersey's independent regulator for information rights.

Claims (4):

  • The JDPA is a statutory body established under the DPAJL 2018 to act as Jersey's independent regulator to uphold information rights in the public interest, promote openness by public bodies and data privacy for individuals; JOIC is its operational name.
  • Article 15 of the DPAJL 2018 requires the JDPA to develop international cooperation mechanisms and provide international mutual assistance in enforcement of data-protection legislation, including via notification, complaint referral, investigative assistance and information exchange.
  • Jersey Information Commissioner (Paul Vane) — The JOIC's 2026-2028 Strategic Plan on 2 February 2026, built on three priorities (Children's Privacy, AI in HR, Cyber Security) and an Advise/Assess/Act enforcement model, stating enforcement action will be taken without delay for clear non-compliance.
  • Jersey Data Protection Authority — The Authority's functions are delegated to the Information Commissioner save for the issuing of a formal public statement or an administrative fine, which remain Authority-level decisions.

Act And InstrumentsAmber

Twin-statute structure (DPJL 2018 + DPAJL 2018), enacted in 2018 to preserve EU adequacy while diverging from GDPR in several particulars.

Claims (1):

  • Jersey introduced two companion statutes in 2018 — the Data Protection (Jersey) Law 2018 and the Data Protection Authority (Jersey) Law 2018 (collectively 'the Jersey Laws') — built on the foundations of prior Jersey data-protection legislation, enacted with the intention of preserving the Island's pre-existing EU adequacy status.

Material ScopeRed

General GDPR-equivalent material scope is assumed by practitioners but the precise statutory definitions were not independently retrieved.

Claims (1):

  • The precise statutory definitions of 'personal data' and 'processing' under DPJL 2018 Article 1 were not independently retrieved; practitioner commentary assumes GDPR-equivalent material scope.

Territorial ScopeAmber

Jersey defines establishment and the representative duty differently from GDPR Art 3/27, and Jersey sits outside the scope of the UK's own DPA 2018/adequacy decision.

Claims (2):

  • Jersey's data protection laws define 'establishment' differently from the GDPR given Jersey's geographical and legal status, and require appointment of a local representative only where a controller or processor uses equipment in Jersey, a narrower trigger than the GDPR Art 3(2) targeting/monitoring test.
  • The UK's Data Protection Act 2018 and the EU's UK-adequacy decision (Commission Implementing Decision (EU) 2021/1772) do not extend to the British Crown Dependencies, meaning Jersey operates a legally separate data-protection regime rather than inheriting the UK's framework or its EU adequacy.

Regulator Registration And FilingAmber

Mandatory controller registration with JOIC is retained, unlike the EU's post-GDPR abolition of general notification; fee schedule unconfirmed.

Claims (2):

  • Jersey law retains a mandatory registration requirement with JOIC for controllers, a feature that distinguishes it from the GDPR's abolition of general notification obligations.
  • Jersey Data Protection Authority — All data controllers processing personal data in Jersey must register annually with the JDPA; 2026 renewal window ran 1 January-28 February 2026; a revised registration fee model was under consultation December 2025-February 2026.
Category narrative 120 words

Jersey operates a GDPR-aligned omnibus regime built on two companion statutes: the Data Protection (Jersey) Law 2018 (DPJL 2018), the substantive code, and the Data Protection Authority (Jersey) Law 2018 (DPAJL 2018), which establishes the Jersey Data Protection Authority (JDPA), operating under the public-facing name the Jersey Office of the Information Commissioner (JOIC). Jersey is a Crown Dependency, not part of the UK or EU, and is not directly bound by either the EU GDPR or the UK GDPR/DPA 2018 — the UK's own adequacy decision and DPA 2018 expressly do not extend to the Bailiwick. Jersey's territorial-scope test (establishment, representative duty keyed to use of equipment in Jersey) and its retained controller-registration duty diverge from the post-2018 EU/UK approach.

Periodic update · new data 2026-10-25

Regulator & Framework

The Jersey Office of the Information Commissioner, under Commissioner Paul Vane, launched its 2026-2028 Strategic Plan on 2 February 2026. The plan is built around three named priorities — Children's Privacy, Artificial Intelligence in HR decision-making, and Cyber Security — and is delivered through an Advise, Assess, Act operating model. Commissioner Vane's own framing of the plan was explicit about enforcement intent: the Commission stated that the underlying Data Protection (Jersey) Law has been in force for years and that enforcement action will be taken without delay where clear non-compliance is identified, framing continued non-compliance as a choice to leave an organisation exposed to enforcement rather than as an oversight the regulator will continue to tolerate.

This is a structural statement about supervisory posture rather than a change to the substantive law. The Data Protection (Jersey) Law 2018 itself is unchanged; what the Strategic Plan does is commit the regulator publicly to a faster and more assertive enforcement cadence than organisations may have experienced in prior years. The three named priorities also indicate where that assertive posture will be concentrated: children's privacy, AI used in employment contexts, and cybersecurity assessment, rather than being spread evenly across the full range of data-protection obligations.

On the administrative side of the regulator-and-framework picture, Jersey's annual registration requirement continued to operate on its normal cycle. All data controllers processing personal data in Jersey must register annually with the Jersey Data Protection Authority, and the 2026 renewal window ran from 1 January to 28 February 2026. A revised registration fee model, covering both public and private sector registrants, was put out for consultation from December 2025 to February 2026. The outcome of that consultation — whether a revised fee schedule was in fact adopted, and on what terms — has not been identified in the material available, leaving the final shape of the 2026 fee model an open question for registrants budgeting for the next renewal cycle.

Taken together, the Strategic Plan launch and the registration-fee consultation describe a regulator simultaneously sharpening its enforcement posture and reviewing its own administrative funding model, two developments that often move together: a regulator signalling more assertive enforcement activity also has reason to review whether its registration-fee income is adequate to support that activity.

Outlook

The practical test of the 2026-2028 Strategic Plan's Advise, Assess, Act model will be whether the enforcement tempo evidenced through mid-2026 is sustained over the plan's full three-year horizon. The outcome of the registration fee-model consultation remains unresolved as and should be tracked for whether a revised fee schedule is formally adopted.

Sources and claims (10)
  1. Confirmed ICO / JOIC — The JDPA is a statutory body established under the DPAJL 2018 to act as Jersey's independent regulator to uphold information rights in the public interest, promote openness by public bodies and data privacy for individuals; JOIC is its operational name. observed
  2. Probable DataGuidance — Jersey introduced two companion statutes in 2018 — the Data Protection (Jersey) Law 2018 and the Data Protection Authority (Jersey) Law 2018 (collectively 'the Jersey Laws') — built on the foundations of prior Jersey data-protection legislation, enacted with the intention of preserving the Island's pre-existing EU adequacy status. observed
  3. Probable DataGuidance — Jersey's data protection laws define 'establishment' differently from the GDPR given Jersey's geographical and legal status, and require appointment of a local representative only where a controller or processor uses equipment in Jersey, a narrower trigger than the GDPR Art 3(2) targeting/monitoring test. observed
  4. Probable DataGuidance — Jersey law retains a mandatory registration requirement with JOIC for controllers, a feature that distinguishes it from the GDPR's abolition of general notification obligations. observed
  5. Uncertain DataGuidance — The precise statutory definitions of 'personal data' and 'processing' under DPJL 2018 Article 1 were not independently retrieved; practitioner commentary assumes GDPR-equivalent material scope. observed
  6. Confirmed EUR-Lex — The UK's Data Protection Act 2018 and the EU's UK-adequacy decision (Commission Implementing Decision (EU) 2021/1772) do not extend to the British Crown Dependencies, meaning Jersey operates a legally separate data-protection regime rather than inheriting the UK's framework or its EU adequacy. observed
  7. Confirmed ICO / JOIC — Article 15 of the DPAJL 2018 requires the JDPA to develop international cooperation mechanisms and provide international mutual assistance in enforcement of data-protection legislation, including via notification, complaint referral, investigative assistance and information exchange. observed
  8. Confirmed https://jerseyoic.org/news/the-ink-dried-on-data-protection-law-years-ago-if-you-re-not-compliant-you-re-leaving-yourself-open-to-enforcement-action — Jersey Information Commissioner (Paul Vane) — The JOIC's 2026-2028 Strategic Plan on 2 February 2026, built on three priorities (Children's Privacy, AI in HR, Cyber Security) and an Advise/Assess/Act enforcement model, stating enforcement action will be taken without delay for clear non-compliance.
  9. Probable https://jerseychamber.com/news/data-protection-registration-renewal-now-open-2026 — Jersey Data Protection Authority — All data controllers processing personal data in Jersey must register annually with the JDPA; 2026 renewal window ran 1 January-28 February 2026; a revised registration fee model was under consultation December 2025-February 2026.
  10. Probable DLA Piper Data Protection Laws of the World — Jersey Data Protection Authority — The Authority's functions are delegated to the Information Commissioner save for the issuing of a formal public statement or an administrative fine, which remain Authority-level decisions. observed

#

No primary-instrument pinpoint located for lawful bases, consent thresholds or pseudonymisation tests; only one enforcement-derived special-category reference confirmed.

Primary frameworkData Protection (Jersey) Law 2018
Traffic-light rationale — RedNo primary-instrument pinpoint located for lawful bases, consent thresholds or pseudonymisation tests; only one enforcement-derived special-category reference confirmed.
D2 · Lawful Processing — Full Module Record4 sub-modules · 65 words · 3 traced claims · Re-verified 2026-10-25

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#

One confirmed directional finding (shorter SAR window) at T3 confidence; remaining sub-modules unpopulated.

Primary frameworkData Protection (Jersey) Law 2018
Traffic-light rationale — AmberOne confirmed directional finding (shorter SAR window) at T3 confidence; remaining sub-modules unpopulated.

Sub-modules (5)

Access RightAmber

SAR response period confirmed shorter than GDPR's one month; exact figure not retrieved.

Claims (2):

  • The statutory response period for subject access requests under Jersey's Data Protection (Jersey) Law 2018 is shorter than the GDPR's one-month standard, per practitioner comparison, though the precise number of days was not confirmed from primary legislation in this pass.
  • Jersey Office of the Information Commissioner — New guidance explaining biometric data and special-category biometric data concepts and how the Data Protection (Jersey) Law 2018 applies when such data is used.

Rectification And ErasureRed

Not located in this pass.

Claims (1):

  • No primary or secondary source was located in this pass confirming the specific grounds/exceptions for erasure, the compelling-legitimate-grounds test for restriction/objection, or the scope of any portability right under Jersey law.

Restriction And ObjectionRed

Not located in this pass.

Claims (1):

  • No primary or secondary source was located in this pass confirming the specific grounds/exceptions for erasure, the compelling-legitimate-grounds test for restriction/objection, or the scope of any portability right under Jersey law.

Data PortabilityRed

Not located in this pass.

Claims (1):

  • No primary or secondary source was located in this pass confirming the specific grounds/exceptions for erasure, the compelling-legitimate-grounds test for restriction/objection, or the scope of any portability right under Jersey law.

Deadlines And Response WindowsAmber

Shorter-than-GDPR SAR deadline confirmed directionally; precise figure outstanding.

Claims (1):

  • The statutory response period for subject access requests under Jersey's Data Protection (Jersey) Law 2018 is shorter than the GDPR's one-month standard, per practitioner comparison, though the precise number of days was not confirmed from primary legislation in this pass.
Category narrative 36 words

Practitioner commentary confirms Jersey's DSAR response window is shorter than the GDPR's one-month standard, but the precise day-count was not retrieved from primary legislation. Erasure, restriction/objection and portability provisions were not independently located in this pass.

Sources and claims (3)
  1. Probable DataGuidance — The statutory response period for subject access requests under Jersey's Data Protection (Jersey) Law 2018 is shorter than the GDPR's one-month standard, per practitioner comparison, though the precise number of days was not confirmed from primary legislation in this pass. observed
  2. Uncertain DataGuidance — No primary or secondary source was located in this pass confirming the specific grounds/exceptions for erasure, the compelling-legitimate-grounds test for restriction/objection, or the scope of any portability right under Jersey law. observed
  3. Uncertain https://www.linkedin.com/company/office-information-commissioner — Jersey Office of the Information Commissioner — New guidance explaining biometric data and special-category biometric data concepts and how the Data Protection (Jersey) Law 2018 applies when such data is used.

#

Breach notification and security principle well evidenced; five of seven sub-modules unpopulated.

Primary frameworkData Protection (Jersey) Law 2018
Traffic-light rationale — AmberBreach notification and security principle well evidenced; five of seven sub-modules unpopulated.
D4 · Controller & Processor — Full Module Record7 sub-modules · 44 words · 5 traced claims · Re-verified 2026-10-25

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#

Adequacy received (both EU and UK, general and law-enforcement) is strongly evidenced at T1; transfer-mechanism mechanics beyond adequacy are a gap.

Primary frameworkCommission Decision 2008/393/EC; GDPR Art 97; UK DPA 2018 Schedule 21 / s.74A
Traffic-light rationale — GreenAdequacy received (both EU and UK, general and law-enforcement) is strongly evidenced at T1; transfer-mechanism mechanics beyond adequacy are a gap.
D5 · Cross-Border & Adequacy — Full Module Record6 sub-modules · 132 words · 9 traced claims · Re-verified 2026-10-25

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#

One concrete, dated sectoral finding (credit-scoring data sharing); seven of eight sub-modules unpopulated.

Primary frameworkData Protection (Jersey) Law 2018 (sectoral application); Population Register legislative amendment (Jersey, Jan 2026)
Traffic-light rationale — AmberOne concrete, dated sectoral finding (credit-scoring data sharing); seven of eight sub-modules unpopulated.
D6 · Sectoral Watch — Full Module Record8 sub-modules · 73 words · 3 traced claims · Re-verified 2026-10-25

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Entire module rests on an inference from the UK's non-extension rather than a located Jersey instrument.

Traffic-light rationale — RedEntire module rests on an inference from the UK's non-extension rather than a located Jersey instrument.
D7 · AdTech & Marketing — Full Module Record6 sub-modules · 67 words · 2 traced claims · Re-verified 2026-10-25

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#

Entire module unpopulated by primary or secondary Jersey-specific sources.

Traffic-light rationale — RedEntire module unpopulated by primary or secondary Jersey-specific sources.
D8 · AI, Biometrics & Automated — Full Module Record6 sub-modules · 35 words · 4 traced claims · Re-verified 2026-10-25

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#

Entire module unpopulated by primary or secondary Jersey-specific sources.

Traffic-light rationale — RedEntire module unpopulated by primary or secondary Jersey-specific sources.
D9 · Children's Privacy — Full Module Record5 sub-modules · 19 words · 2 traced claims · Re-verified 2026-10-25

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#

Powers and one concrete enforcement precedent are well evidenced at T2/T3; penalty quantum, funding and redress-mechanism sub-modules are gaps.

Primary frameworkData Protection Authority (Jersey) Law 2018
Traffic-light rationale — AmberPowers and one concrete enforcement precedent are well evidenced at T2/T3; penalty quantum, funding and redress-mechanism sub-modules are gaps.
Periodic update · new data 2026-10-25

Enforcement & Redress

The Jersey Office of the Information Commissioner issued multiple decision notices against Jersey government departments through the first half of 2026: against Infrastructure and Environment on 25 June 2026, against the Department for the Economy on both 13 May 2026 and 25 June 2026, and against the Judicial Greffe on 15 June 2026. These decision notices are drawn directly from the JOIC's own published decision-notices material and represent concrete enforcement output rather than a stated intention to enforce.

This enforcement activity sits directly alongside, and substantiates, the more assertive posture articulated in the Commissioner's public statements. On International Data Protection Day 2026, 2 February 2026, Commissioner Paul Vane reaffirmed that enforcement action would be taken without delay where risks to Islanders are identified, a statement reported by Channel Eye and consistent with the enforcement activity that followed in the months immediately after. Reading the decision notices and the public statement together, the evidence supports a reading that the JOIC is not merely stating an intent to enforce more assertively but has, within the same calendar year, demonstrated that intent against multiple public-sector controllers.

The concentration of decision notices against government departments specifically — rather than private-sector controllers — is itself notable: it signals that the JOIC's assertive posture extends to public bodies as readily as to the private sector, which is a meaningful signal for any organisation, public or private, assessing how seriously to treat its own data-protection compliance obligations under the Data Protection (Jersey) Law 2018.

What remains unconfirmed is the detail of the underlying compliance failures that gave rise to each notice, and the current maximum fine-tier structure under the Data Protection (Jersey) Law was not independently re-verified this period. The decision notices identified are therefore recorded as enforcement activity events; the substantive findings within each notice were not separately assessed.

Outlook

Given the pace of decision notices issued against government departments through mid-2026 and the Commissioner's stated intent to continue swift enforcement, continued enforcement activity should be expected over the remainder of the 2026-2028 Strategic Plan period. Whether that activity extends with similar frequency to private-sector controllers, as distinct from the public-sector concentration observed, is the specific pattern to track going forward.

D10 · Enforcement & Redress — Full Module Record6 sub-modules · 99 words · 10 traced claims · Re-verified 2026-10-25

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No categories match.

Filters combine as OR inside a group and AND across groups.

Provenance and declared absence

Disclosure model: category cards load OPEN; narratives render in full; standing narratives load as a clamped teaser with an explicit “read full” control carrying the true word count. No text is hidden without disclosing how much of it there is.

Sub-modules are DP-specific nested subsections with their own real per-sub-module traffic light, rendered under each category across all regulatory modules.

Traffic-light dots are REAL data (baseline.<category>.traffic_light), not renderer-invented taxonomy, and are never suppressed -- unlike WPM, where a RAG dot would be forbidden as invented severity.

Family/accent taxonomy is renderer-level presentation config, not a JID field; it decorates the RAG dot, it does not replace it. Colour is always duplicated in text and is never the sole carrier of meaning.

Suppressed by doctrine: derived risk score. Not shown on this page.

Band honesty: uncertainty bands are computed against a frozen build clock of 2026-11-04. A year-precision row is never promoted into a tighter band.

Envelope: baseline resolved at jurisdiction_json.baseline; 10 categories, 58 sub-module(s), 51 claim(s) (51 category placement(s)), 22 source(s) in the cumulative register.

Audit trail

Machine checkChallenged on 24 Oct 2026: not upheld (8 confirmed against the cited source; 1 contradicted by the cited source; 2 could not be checked). An automated, adversarial test run by a second model; no person has assessed the result.

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GDPR article map

Cross-reference: which category/sub-module covers each UK GDPR article (38 mapped).

Show article map
GDPR article to category mapping
ArticleCategorySub-module
Art. 5Controller/Processor Dutiesaccountability and dpia
Art. 6Lawful Processing & Special Datalawful bases
Art. 7Lawful Processing & Special Dataconsent thresholds
Art. 9Lawful Processing & Special Dataspecial categories
Art. 13Data Subject Rightsdeadlines and response windows
Art. 14Data Subject Rightsdeadlines and response windows
Art. 15Data Subject Rightsaccess right
Art. 16Data Subject Rightsrectification and erasure
Art. 17Data Subject Rightsrectification and erasure
Art. 18Data Subject Rightsrestriction and objection
Art. 19Data Subject Rightsrectification and erasure
Art. 20Data Subject Rightsdata portability
Art. 21Data Subject Rightsrestriction and objection
Art. 22Algorithmic, Biometric & Surveillance Governanceautomated decision making transparency
Art. 25Controller/Processor Dutiesaccountability and dpia
Art. 28Controller/Processor Dutiesjoint controller arrangements
Art. 30Controller/Processor Dutiesropa requirements
Art. 32Controller/Processor Dutiessecurity measures
Art. 33Controller/Processor Dutiesbreach notification
Art. 34Controller/Processor Dutiesbreach notification
Art. 35Controller/Processor Dutiesaccountability and dpia
Art. 37Controller/Processor Dutiesdpo requirements
Art. 38Controller/Processor Dutiesdpo requirements
Art. 39Controller/Processor Dutiesdpo requirements
Art. 44Cross-Border & Adequacytransfer mechanisms
Art. 45Cross-Border & Adequacyadequacy received
Art. 46Cross-Border & Adequacysccs and bcrs
Art. 47Cross-Border & Adequacysccs and bcrs
Art. 48Cross-Border & Adequacytransfer mechanisms
Art. 49Cross-Border & Adequacytransfer mechanisms
Art. 77Enforcement & Redressprivate right of action
Art. 78Enforcement & Redressprivate right of action
Art. 79Enforcement & Redressprivate right of action
Art. 80Enforcement & Redresscollective redress and class actions
Art. 81Enforcement & Redressregulator powers and penalties
Art. 82Enforcement & Redressprivate right of action
Art. 83Enforcement & Redressregulator powers and penalties
Art. 84Enforcement & Redressregulator powers and penalties