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A case study in GDPR Article 3 and supporting recitals: Why not get ready for the GDPR (or other global-reaching DP laws) to apply to your non-EU business?
Journal of Data Protection & Privacy,
2
(1),
6-15
(2018)
Abstract
In the Gulf Cooperation Council region (the GCC), a growing global business hub, the applicability of the General Data Protection Regulation (GDPR) is undeniable, as it is in most jurisdictions. There are, however, a fair few businesses that directly control and process EU personal data that are not yet clear on their obligations under the GDPR. This paper explores applicability under Article 3 in particular. It also contains an interview with the Dubai International Financial Center Data Protection Commissioner, who enforces data protection regulations of this federal free zone in Dubai. If your Middle Eastern business (or subsidiary) is not sure whether to prepare for the GDPR, this paper will help clarify any remaining questions in that regard.
Keywords: Middle East; General Data Protection Regulation (GDPR); applicability; Article 3; Dubai International Financial Centre (DIFC)
The full article is available to subscribers to the journal.
Author's Biography
Lori Baker is an experienced attorney with expertise in data protection and regulatory compliance, as well as broad practice in commercial contracting. She is qualified in both the USA (in the states of New Jersey and Pennsylvania) and the UK, and relocated to Dubai in October 2016. Upon arrival in Dubai, she provided temporary compliance and commercial drafting support in the legal team at Careem and then as Group Legal and Compliance Counsel for Moby Media FZ LLC until April 2018. Lori now provides data protection and security strategy and support in one of the leading financial centres in the MEASA region. Prior to relocating, Lori was based in London, UK for 10 years, having worked most recently for Fieldfisher LLP in the technology and outsourcing team as a senior privacy and cybersecurity associate. She held in-house roles as senior compliance and privacy counsel at Dun & Bradstreet, head of ethics at Orange Business Services and global regulatory/privacy specialist and senior compliance project manager at BT Global Services. In addition, Lori was an adjunct professor of philosophy at Brookdale Community College in New Jersey. She also practised in mass torts and consumer fraud litigation as a plaintiff’s attorney with Seeger Weiss LLP in New York City. Lori attended DeSales University, receiving a Bachelor of Arts in politics with a minor in philosophy, followed by Widener University School of Law (the Delaware Law School), where she was awarded a Juris Doctor with an emphasis in international business transactions. While at Widener, Lori enrolled in the Geneva International Law Institute, directed by instructors from the WTO, the UN and other international organisations.
