Privacy 2040: An initiative for collaboration between policymakers and businesses

We are announcing the launch today of Privacy 2040, Hogan Lovells’ initiative aimed at shaping the future of privacy and cybersecurity frameworks and practices to support innovation and protect humanity.



It’s a big aim, so this is an ambitious, long-term project. Let us explain.

Why Privacy 2040?

The tension between the unstoppable evolution of technology and the efforts by legislators, regulators and the courts to safeguard people’s privacy in the data economy creates an opportunity to take a stand and find solutions.

Through Privacy 2040, we will use our leadership in this area to bring together those tackling this issue and help support innovation as well as the adoption of responsible, forward-looking privacy and cybersecurity practices.

What is Privacy 2040?

Privacy 2040 will involve:

  • In-depth strategic discussions with businesses about the impact of existing and future privacy and cybersecurity regulatory frameworks on their organizations and goals.
  • Proactive engagement with policy makers, legislators and regulators in the form of written papers, one-to-one meetings, round-table discussions and events.
  • Engagement with the media and the wider world by way of thought leadership about privacy and cybersecurity.

What issues will Privacy 2040 deal with?

Time will tell, but Initial analysis from Hogan Lovells reveals potential concerns over the following types of issues:

  • The legal justification for global uses of personal information – from the role of consent to public and legitimate interests.
  • The current and forthcoming regulation of tech developments such as AI, facial recognition and connected devices.
  • The practical implementation of the Data protection by design and by default legal requirement to bear data protection in mind from the design stage right through a product’s lifecycle.
  • The process for regulatory recognition and approval of international data transfers mechanisms (highlighted by both Brexit and the CJEU “Schrems II” case).
  • The EU ePrivacy framework.
  • The regulatory approach to personalization based on profiling.
  • In relation to Brexit, the future of the UK legal framework and privacy regulator.

In a nutshell, with Privacy 2040, we are contributing our leadership in privacy and cybersecurity to help create an environment where new technologies, business practices and regulation work in harmony to create a prosperous and sustainable future.


Authored by Eduardo Ustaran and Marcy Wilder


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