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ICO’s Serco enforcement for biometric data use – what employers need to know The Information Commissioner’s Office (ICO) has announced that Serco Leisure and associated organisations have been issued with enforcement notices ordering them to stop using facial recognition technology and fingerprint scanning to monitor employee atte... Firm Foundations: Taking Stock of BlackRock In the spirit of adventure, or my sapless version of it, I asked ChatGPT 3.5 to propose some puns to deploy in the title of this post. The results ranged from the dull to the surreal. (And some results were both dull and surreal… “Between a Rock and a Tax... Hargreaves Property Holdings v HMRC: Ramsay reigns supreme In Hargreaves Property Holdings Limited v HMRC, the Court of Appeal dismissed the taxpayer’s appeal against the Upper Tribunal’s decision (which I covered in a blog post here). The taxpayer had initially appealed to the Upper Tribunal against the FTT’s de... Who’s got the power?  The paradox of power-hungry data centres As the world grapples with fuel shortages, increased and volatile energy prices and an urgent need to transition to renewables, Governments and regulators across the globe continue to turn their lens on data centres and other digital infrastructure provid... "This is not a drill" - DSIT publishes Responsible AI Toolkit On 24 March 2024, the Department for Science, Innovation and Technology (DSIT) published its Responsible AI Toolkit (the “Toolkit”) - a repository for the latest guidance and research in responsible AI development and use.  The Toolkit was developed by th... CMA updates AI Foundation Model principles amid concerns about how the sector is developing Last week, the CMA published an update to its initial report on AI Foundation Models published last September.  The initial report has been widely praised, with stakeholders and practitioners commending the CMA for its work to understand these complex mar... New ICO fining guidance and an update on the ICO's enforcement approach The sheer number of cases facing potential enforcement coupled with the shifting versions of draft guidance have, in recent years, made it hard to predict what (if any) action the ICO would take and when (if at all) an investigation might be concluded. Th... Cyber update – what’s been happening in Q1 2024 As Q1 2024 comes to a close, I look back at some of the key cyber developments that have been keeping us, and our clients, busy so far this year: UK organisations more likely to pay ransoms:  We are continuing to advise clients on ransomware attacks, and ... Who’s who? ICO clarifies rules for biometric recognition Facial recognition has been in the headlines over the last year, both in usage by police and more widely, such as shops identifying known shoplifters and by employers monitoring employees. Most recently its been in the news because the ICO has required Se... Recent developments in respect of the Italian investment management exemption regime Does an Italian investment manager create a permanent establishment for a foreign investment vehicle? Not necessarily – especially now that the investment management exemption (IME) has been implemented. The IME is an important safe harbour for the invest...