Hi, I'm Rob.

And I'm Megan.

We're both European privacy lawyers at Fieldfisher and we'll be delivering the bite-sized legal update for you today.

Megan, what's our topic?

Today we'll be talking about the Swedish regulators enforcement action against various companies' use of Google Analytics.

Oh dear, not another Google Analytics decision.

I'm having deja vu.

Or didn't we hear enough about that last year?

We did.

And there's more.

Last year we saw decisions from the French, Italian and Austrian data protection regulators

off the back of a series of NYB complaints against 101 companies across Europe. So, Google Analytics. Can you use it? Can

you not? And what do the EU authorities have to say? Before we get started, Rob, perhaps it's helpful if you can first give us a bit of background to the decisions.

Sure. So there were four companies in these decisions. Two of them, Degans and Co-op, were not fined, whereas the other two, Tully 2 and CD-O-N were fined.

Which should also say that three of the companies were also ordered to stop using their version of the Google Analytics that they've been using at the time of the complaint,

and less adequate safeguards could be put in place. The other had already stopped using it.

But the Rawlings didn't ban Google Analytics altogether.

That's correct. And what's interesting about the decision is it left open the possibility to continue using Google Analytics.

But presumably under some conditions.

Exactly. So by looking at these four decisions, we can identify a few themes as to why two of the companies were fined and two were not. And it really all comes down to some basic GDPR principles

and following the guidance of the EDPB. So as our listeners will be aware, the Schrems 2 case

and the EDPB guidance which followed that said a lot of things,

...