Welcome back to the Trace podcast, Brides, Swindle, or Steel.

I'm Alexandra Rogge.

Today we'll hear from Paul Lavery.

Paul is the head of McCann Fitzgerald's Technology and Innovation Group.

Based in Dublin, he has extraordinary expertise in data protection and has been working with Trace for two years as we've navigated the GDPR.

Paul recently spoke to Trace member companies about the GDPR and how member states are addressing impediments to anti-bribery due diligence.

Here's Paul.

What I'm going to talk about here today is an issue that arises under the GDPR in relation

to anti-bribery due diligence.

I'm going to explain what that issue is and I'm going to explain the steps that some member

states are taking to address the issue.

The spoiler alert is that there is an issue with anti-bribery

due diligence at the moment. And there is an issue in circumstances where that anti-bribery due

diligence results in processing. And what I mean by processing is any type of review or access

to either special category data, and that includes data relating

to political opinions, religious beliefs, etc. And also in circumstances where it relates

to criminal convictions or criminal offences. And in those circumstances, unless that is authorized or mandated by European Union law or

the law of a member state, it's prohibited under the GDPR.

The problem that has arisen is that has effectively been unknown to the relevant people who specialize in GDPR

at a European level. And the potential reason for that is you apparently seem to have two

parallel strategies at Europe. You've got the people who specialize in dealing with anti-bribery and anti-corruption.

And then you've got another silo of people who focus on privacy.

...