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I'm a lurker on your blog, and I admit to not having expert knowledge about this area, but...

I don't know whether you were as shocked as I was by the tone of the speech. It seems to suggest the MoJ is pretty unwilling to engage constructively with the Commission proposals.

Also, I wonder whether you've seen the EU FRA report on national data protection systems, which suggests to me both the EU is justified in approaching this in a more "one size fits all" way than they may otherwise do, as well as making plain for all to see serious problems both in MoJ and ICO:

Sorry for posting so late, but just came across this too, which indicates the Government's position. Thought it may be useful as a link:

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