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Eduardo Ustaran

@eustaran.bsky.social
284 followers 98 following 372 posts

Privacy, data protection and digital regulation lawyer, pragmatic thinker and author

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Eduardo Ustaran @eustaran.bsky.social · 22/09/2026
This can only be a good thing and perhaps the closest we can get today to effective and pragmatic global regulation aimed at realising the promises of AI.
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Eduardo Ustaran @eustaran.bsky.social · 03/09/2026
What can AI engineers and AI governance professionals learn from marathon running? Some thoughts on finding a winning formula. www.linkedin.com/pulse/art-pa...
linkedin.com
The art of pacing
In the past year, approximately 1.5 million people worldwide are estimated to have run a marathon.
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Eduardo Ustaran @eustaran.bsky.social · 06/08/2026
As a runner, I don’t interpret “pacing” as slowing down even if pacing oneself correctly means going more slowly than one could possibly run. As every marathon runner knows, getting the pace right is probably the single most important aspect of a successful outcome. The same principle applies to AI.
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Eduardo Ustaran @eustaran.bsky.social · 22/04/2026
🌍 Adequacy (by the EU and the UK) should ideally be positioned as a way of promoting the ongoing protection of data globally, rather than the pursuit of convergence towards any given standards. All debatable, of course, so other views welcome (either if you see me here in Venice or digitally).
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Eduardo Ustaran @eustaran.bsky.social · 22/04/2026
To reiterate two key points I made: 🌎 There is a risk that if we position the rules around international data transfers as a digital sovereignty issue, we may lose track of the fact that the real intention should be for the protection to follow the data as it flows.
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Eduardo Ustaran @eustaran.bsky.social · 22/04/2026
Quite a venue to discuss international data transfers at the Venice Privacy Symposium this morning.
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Eduardo Ustaran @eustaran.bsky.social · 23/03/2026
Lima. On an early morning run. Attending Global CBPR Forum meetings.
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Eduardo Ustaran @eustaran.bsky.social · 23/03/2026
Mine wasn’t bad either…
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Eduardo Ustaran @eustaran.bsky.social · 19/03/2026
Please don’t be worried. Being afraid of being free is the first step to losing our freedom.
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Eduardo Ustaran @eustaran.bsky.social · 19/03/2026
Great thread about the practical mindset of European top judges.👇
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Eduardo Ustaran @eustaran.bsky.social · 18/03/2026
Doing some domestic filing, I came across this article I wrote as a newly qualified lawyer in June 1996 for the internal newsletter of the first law firm I worked for. Aside from being a blast from the past, the similarities with how we approach the use of AI at law firms today are pretty striking.
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Eduardo Ustaran @eustaran.bsky.social · 16/03/2026
Beyond legal technicalities and appeasement, can Europe pull off the next generation of global digital regulation standards? My latest piece on the real purpose of the EU Digital Omnibus. www.linkedin.com/pulse/what-d...
linkedin.com
What the Digital Omnibus is really about
Law making always happens for a reason. Sometimes that reason is clear, others less so.
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Eduardo Ustaran @eustaran.bsky.social · 13/03/2026
Clearly “Starmer…🎶🎶” to the tune of The Police’s “Roxanne…🎶🎶”
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Eduardo Ustaran @eustaran.bsky.social · 10/03/2026
Our take on where the EU Digital Omnibus is at the moment and what is likely to go through. www.hoganlovells.com/en/publicati...
hoganlovells.com
EU Digital Omnibus – Where simplification is likely and what businesses should plan for
Theongoing progress of the Digital Omnibus legislative reform is beginning to showthat while the EU is not seeking to radically rewrite the data managementrulebook, the various selective adjustments p...
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Eduardo Ustaran @eustaran.bsky.social · 07/03/2026
Maybe the distinction is less about consciousness and more about conscience.
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Eduardo Ustaran @eustaran.bsky.social · 06/03/2026
Wondering what aspects of AI global regulators are acting on?  We discuss it in some depth in this episode of our podcast The Data Chronicles. Perfect for the weekend! www.hoganlovells.com/en/publicati...
hoganlovells.com
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Eduardo Ustaran @eustaran.bsky.social · 27/02/2026
When people hear about the ICO, they often think of @infocommission.bsky.social, but there is another very respectable entity that has the same initials: the Irish Chamber Orchestra. This ICO has today released a wonderful album that is just food for your soul. open.spotify.com/album/27pXTn...
open.spotify.com
Invitation: Mozart, Mendelssohn & Schumann
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Eduardo Ustaran @eustaran.bsky.social · 25/02/2026
Data protection is not just about compliance. It is also about demonstrating compliance, and this is particularly important for regulatory investigations, we hear at #IAPPIntensive26. Transparency is therefore key alongside the ability to maintain confidentiality.
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Eduardo Ustaran @eustaran.bsky.social · 25/02/2026
Not getting the wider strategy right when faced with a regulatory investigation is regarded as the most critical mistake. It sounds obvious but when operating in crisis mode, having the space to think is lacking precisely when it is most important. Wise views at #IAPPIntensive26.
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Eduardo Ustaran @eustaran.bsky.social · 25/02/2026
A complaint that is not amicably resolved and is escalated to a regulator is seen as one of the most common triggers of a formal regulatory investigation at #IAPPIntensive26. So avoiding escalation should be seen as a priority in practice.
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Eduardo Ustaran @eustaran.bsky.social · 25/02/2026
Fascinating session at #IAPPIntensive26 focused on the sensitive topic how to handle regulatory investigations. First lesson to learn is that from the very first interaction with a regulator, no matter how informal or casual, the right attitude matters.
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Eduardo Ustaran @eustaran.bsky.social · 25/02/2026
Wise words by my colleague Charmian Aw at #IAPPIntensive26 explaining how a legal framework focused on enhancing trust is the best ally of innovation.
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Eduardo Ustaran @eustaran.bsky.social · 25/02/2026
The number of people attending this #IAPPIntensive26 session on international data transfers and the number of questions being asked shows what a big area of concern this still is for organisations.
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Eduardo Ustaran @eustaran.bsky.social · 25/02/2026
Interesting panel session at #IAPPIntensive26 comparing the (slight) simplification of the UK’s international data transfers regime with the EU’s (growing) toughening of its own approach.
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Eduardo Ustaran @eustaran.bsky.social · 25/02/2026
The big cheese (and more importantly the big brains) behind the @iapp.bsky.social @jtrevorhughes.bsky.social reflecting over the long evolution of our crucial profession for humanity’s wellbeing and prosperity at #IAPPIntensive26.
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Eduardo Ustaran @eustaran.bsky.social · 25/02/2026
John Edwards of @infocommission.bsky.social emphasises the crucial importance of being agile in order to look ahead and anticipate risks. He rightly says at #IAPPIntensive26 that this is aligned with the ability to act in a coordinated fashion with other regulators.
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Eduardo Ustaran @eustaran.bsky.social · 25/02/2026
Commissioner John Edwards vigorously defends the @infocommission.bsky.social regulatory strategy and resource allocation, and explains at #IAPPIntensive26 that their decisions about any trade offs made when pursuing some objectives over others are fully transparent.
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Eduardo Ustaran @eustaran.bsky.social · 25/02/2026
A familiar face kick-starting #IAPPIntensive26 telling us about the changes happening at the @infocommission.bsky.social and reflecting about the importance of resilient and agile regulators in the age of AI.
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Eduardo Ustaran @eustaran.bsky.social · 20/02/2026
On a fleeting visit to San Francisco, local companies are very keen to know how far the European digital regulatory simplification will go. You could call that part of the “Brussels Effect”.
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Eduardo Ustaran @eustaran.bsky.social · 17/02/2026
Sharp reporting on the state of play of the critical issue of copyright and AI training in the UK by my colleagues. www.hoganlovells.com/en/publicati...
hoganlovells.com
AI and copyright: UK outlook for 2026
In this article we take a look at what to expect in 2026 in the area of AI and UK copyright, including key judgments, legislative proposals and other developments on the horizon.
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Eduardo Ustaran @eustaran.bsky.social · 11/02/2026
And since AI governance needs to work across jurisdictions with different legal regimes, as has been the case with privacy governance for years, it is also crucial to identify a common denominator (not too low and not too high) that can be used a global standard (even if local tweaks are needed).
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Eduardo Ustaran @eustaran.bsky.social · 11/02/2026
Devising a clear, sensible and workable risk triage process is equally essential in practice. The trick is to reach consensus on what the real risks could be, but the most obvious business risk of AI is to invest into AI that doesn’t deliver its benefits because it doesn’t work or is unlawful.
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Eduardo Ustaran @eustaran.bsky.social · 11/02/2026
The number one mission of those with responsibility for AI governance is to convey the message that “AI governance is an enabler, not a blocker”. This obviously has to be a genuinely believed message which has to be backed up by actions that show it’s true.
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Eduardo Ustaran @eustaran.bsky.social · 11/02/2026
A few reflections on AI Governance.👇 A very common pattern I keep seeing is businesses feeling under pressure to implement AI tools and those with responsibility for AI governance becoming sidelined by those businesses for fear that they will slow things down. We need to change this dynamic.
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Eduardo Ustaran @eustaran.bsky.social · 05/02/2026
When the sunrise is really the moonset.
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Eduardo Ustaran @eustaran.bsky.social · 28/01/2026
If this initiative is able to help us all properly understand what AI can and cannot do, it will be a truly successful one. www.gov.uk/government/p...
gov.uk
AI Skills for Life and Work: summary report
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Eduardo Ustaran @eustaran.bsky.social · 27/01/2026
One of the ways in which the UK is expected to specifically regulate #AI is in relation to live facial recognition for law enforcement purposes. Not a bad idea given the level of privacy intrusiveness, but very unlikely to become a “prohibited AI practice” as in the EU.
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Eduardo Ustaran @eustaran.bsky.social · 27/01/2026
The conversation by @kevinroose.com and @caseynewton.bsky.social with Amanda Askell about how to train an #AI LLM to adopt the right values is so thought provoking at so many levels. This has to be one of the most consequential debates of our time. open.spotify.com/episode/4xFz...
open.spotify.com
Will ChatGPT Ads Change OpenAI? + Amanda Askell Explains Claude's New Constitution
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Eduardo Ustaran @eustaran.bsky.social · 26/01/2026
Those developing or seeking to deploy high-risk #AI systems now need to decide whether to spend the next 6 months preparing for compliance or to take the view that implementation will be delayed and stay put for now. Not an easy decision but at least a middle ground approach would be prudent.
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Eduardo Ustaran @eustaran.bsky.social · 26/01/2026
This is very telling and may lead to split the section of the #AI Act Omnibus dealing with timings from the section dealing with material changes, as otherwise it may not pass on time before the high-risk AI systems obligations kick in this Summer.👇
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Eduardo Ustaran @eustaran.bsky.social · 24/01/2026
Anyone doing the #BigGardenBirdWatch this weekend? I hope this little rascal doesn’t sabotage my efforts…
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Eduardo Ustaran @eustaran.bsky.social · 21/01/2026
In a world where tensions and disagreements appear to be on the increase, this is welcome news that shows how international collaboration on data protection matters leads to practical benefits for businesses and individuals. www.hoganlovells.com/en/publicati...
hoganlovells.com
QFC, DIFC and ADGM advance regional data protection cooperation through mutual adequacy recognition
The Qatar Financial Centre (QFC), Dubai International Financial Centre (DIFC), and Abu Dhabi Global Market (ADGM) have taken a significant step forward in regional regulatory cooperation by mutually r...
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Eduardo Ustaran @eustaran.bsky.social · 20/01/2026
Our take on the new draft requirements for Processor BCR. The EDPB has certainly raised the bar, but with everything going on in the world right now, the “holy grail” of lawful data flows is about to become even more important and sought after. www.hoganlovells.com/en/publicati...
hoganlovells.com
Processor BCR gets an upgrade: Inside the EDPB’s new draft recommendations
The European Data Protection Board (EDPB)has adopted its draftRecommendations 1/2026 on Binding Corporate Rules for Processors (BCR-P)(“Recommendations”). The draft Recommendations aim to update and r...
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Eduardo Ustaran @eustaran.bsky.social · 13/01/2026
Kudos to @infocommission.bsky.social for its impressive report on agentic #AI its data protection implications for several reasons: 1️⃣Super-comprehensive insights of agentic AI. 2️⃣Thorough & realistic legal analysis. 3️⃣Positive mindset about embedding data protection into AI. ico.org.uk/about-the-ic...
ico.org.uk
ICO tech futures: Agentic AI
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Eduardo Ustaran @eustaran.bsky.social · 05/01/2026
Happy New Year to you too. One that already needs an extra dose of optimism and kindness.
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Eduardo Ustaran @eustaran.bsky.social · 05/01/2026
If you are considering your strategic priorities for this year, our last Data Chronicles podcast of 2025, in which we discuss what’s going to be big in 2026 may be a good way to start. Happy New Year! www.hoganlovells.com/en/publicati...
hoganlovells.com
The Data Chronicles: 2025 wrapped and 2026 predictions
In our annual “Look Back, Look Forward” edition of The Data Chronicles, Scott Loughlin and Eduardo Ustaran, co-leads of Hogan Lovells' Global Data, Privacy and Cybersecurity practice, reflect on the m...
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Eduardo Ustaran @eustaran.bsky.social · 18/12/2025
Spotify does it… Strava does it… LinkedIn does it… So here is our 2025 wrapped for you. Our traditional chit chat about what’s been big in privacy, cyber and digital regulation this year and what to look out for in 2026. 🎉 open.spotify.com/episode/5KNy...
open.spotify.com
2025 wrapped and 2026 predictions
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Eduardo Ustaran @eustaran.bsky.social · 18/12/2025
There is a lot to unpack in this piece about the rapidly evolving nature of #AI and our interaction with it, but for me the most telling thing is the scale of our need for emotional support. Not surprising but still telling and something to think about.
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Eduardo Ustaran @eustaran.bsky.social · 18/12/2025
This agentic #AI webinar is a great example of digital regulation in practice. In this respect, the UK should be seen as a role model of how different regulators can collaborate among themselves and engage with businesses to alert them to their responsibilities. www.drcf.org.uk/news-and-eve...
drcf.org.uk
Thematic Innovation Hub: Agentic AI webinar - Recording and Next Steps
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Eduardo Ustaran @eustaran.bsky.social · 12/12/2025
Nothing beats optimism backed by scientific evidence. If the unhealthy geopolitical noise around us ever makes you think that the world is going backwards, don’t despair. Many efforts are still going in the right direction and good things are happening.
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