On 26 July 2019, at the level of the Council, the Finnish government has issued a revised (Council) proposal for the e-Privacy Regulation with some amendments concerning electronic communication content, data & metadata, and further processing of metadata. This proposal will be discussed during a next Council meeting on 9 September 2019.
The Proposal has introduced a limited number of amendments. Most notable:
- Article 6 is divided into four distinct provisions, in order to clarify their respective scope by scope of data (all data, content, metadata).
- Data can only be processed (i) for the duration necessary for the permitted purposes and (ii) if those purposes cannot be fulfilled by processing information that is made anonymous.
- Targeted advertising might not constitute direct marketing communications.