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Portrait of Márton Domokos

Márton Domokos

Co-ordinator of the CEE Data Protection Practice, CMNO

CMS Cameron McKenna Nabarro Olswang LLP Magyarországi Fióktelepe
YBL Palace
Károlyi utca 12
1053 Budapest
Hungary
Languages Hungarian, English
Commercial

Márton is a senior counsel within the commercial team at CMS Budapest, focusing on data protection, intellectual property, commercial transactions and the TMT sector. He is also the Co-ordinator of the CEE Data Protection Practice (CMNO).

He has substantial experience in drafting and negotiating general commercial and IT contracts, advertising, sponsorship and marketing, outsourcing, distribution and franchise agreements, commercial regulatory matters as well as data protection, privacy law and internet law issues.

Márton has spent time working in-house at CMS’ clients. He completed a six month secondment at a global management consulting, technology services and outsourcing company, providing day-to-day legal advice in all projects of the company, working closely with local businesses and the company headquarter’s legal department. He also spent another six month secondment period at the CEE headquarters of a multinational American technology and services conglomerate.. He also completed a seven month secondment in the London headquarters of a global infrastructure, media and financial services company for the financial business unit as the member of the global data privacy team in 2014. Here, he advised on the privacy implications of new products and services, to implement privacy and bank secrecy risk control measures, to analyse global regulatory proposals, and to assist in the development of the data protection compliance programme, including the review of policies and tools.

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"He is a seasoned and highly recognized data privacy lawyer in the Hungarian market. He knows our company and he has always been able to provide us with a tailor-made solution."

Legal 500, 2022

"Standout industry knowledge and personal communication skills make him a real pleasure to work with. Moreover, he delivers concise advice and support to ensure projects are completed on time."

Chambers Europe 2022

"He manages matters absolutely smoothly and is very helpful and always available."

Chambers, 2021

Relevant experience

  • A multinational computer, technology and IT consulting corporation on day-to-day legal matters on region wide commercial, consumer protection, data protection and miscellaneous technology-related issues. Drafting supply, service level, maintenance, standard and specific software development, project and other IT contracts. Supporting IT contract controlling and IT infrastructure library. 6 month secondment at the client’s CEE headquarters in Vienna, supporting the regional legal department.
  • Microsoft on all commercial issues, including general commercial and data protection matters.
  • A leading multinational consumer electronics company on general commercial matters, IP, advertisement, competition, employment, data protection and regulatory issues. Significant works include: the introduction of an on-line music downloading service, the establishment and use of a customer / concerned customer database, drafting general terms and conditions and contractual templates, after-sales consumer service regulations, rules on the acceptance of fully functional or faulty goods, prevention of unfair or anti-competitive market practices, domain name disputes, introduction of anti-bribery procedures, and the establishment of a video hub.
  • A leading technology company on the manufacturing, advertisement and distribution of electronic goods in relation to providing general commercial and regulatory advice. General advice on competition, IP, environmental and product compliance, accomplishment of a product recall in the CEE, compliance with rules on digital switchover, the use of e-signatures and day-to-day e-commerce, compliance with the R&TTE Directive and other special technical regulations, and drafting and negotiating contracts with distributors. Other significant works include: product labelling, product safety, packaging, product charges, energy efficiency, pricing, noise protection, hygienic tests, waste management, warranty obligations, and product liability.
  • Samsung Electronics on all commercial issues, including general commercial matters and regulatory s, as well as establishment of numerous companies, providing day to day legal advice regarding its operations in Hungary.
  • Electronic Arts on general commercial matters and various regulatory issues on a regular basis.
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Education

  • 2012 - LL.M. in U.S. and Global Business Law, Suffolk University, Law School, Hungary
  • 2007 - Postgraduate degree in Infocommunications Law and Technology, University of Pécs, Hungary
  • 2003 - Post-graduate degree in International Trade Law, University of European Studies, Italy
  • 2004 - Degree in Law, Eötvös Loránd University, Hungary
  • 2004 - Degree in Media Studies, University of Szeged, Hungary
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Data Protection & Freedom of Information

Márton is a senior counsel within the commercial team at CMS Budapest, focusing on data protection, intellectual property, commercial transactions and the TMT sector. He is also the Co-ordinator of the CEE Data Protection Practice (CMNO).

Márton has spent time working in-house at CMS’ clients. He completed a six month secondment at a global management consulting, technology services and outsourcing company, providing day-to-day legal advice in all projects of the company, working closely with local businesses and the company headquarter’s legal department. He also spent another six month secondment period at the CEE headquarters of a multinational American technology and services conglomerate. He also completed a seven month secondment in the London headquarters of a global infrastructure, media and financial services company for the financial business unit as the member of the global data privacy team in 2014. Here, he advised on the privacy implications of new products and services, to implement privacy and bank secrecy risk control measures, to analyse global regulatory proposals, and to assist in the development of the data protection compliance programme, including the review of policies and tools.

As part of his regulatory practice, Márton continuously monitors the regulatory developments in data privacy. He regularly gives presentations (Internet Hungary, Jogi Fórum, Infotér) and publishes articles (The Privacy Advisor, Napi Gazdaság, Origo) on privacy issues. He is a regular contributor of DataGuidance, the global privacy compliance service, and a founding member of the Data Protection Board of the Direct and Interactive Marketing Association (FEDMA member).

Márton is recommended by Legal 500 in the TMC category.

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"He is a seasoned and highly recognized data privacy lawyer in the Hungarian market. He knows our company and he has always been able to provide us with a tailor-made solution."

Legal 500, 2022

"Standout industry knowledge and personal communication skills make him a real pleasure to work with. Moreover, he delivers concise advice and support to ensure projects are completed on time."

Chambers Europe 2022

"He manages matters absolutely smoothly and is very helpful and always available."

Chambers, 2021

"This is one of the very few law firms with specific TMT regulatory expertise. Also, the fact that the lawyers understand our business and needs very well is a great benefit."

Chambers, 2016

Relevant experience

  • Microsoft on a full range of legal matters. Significant works include: (i) liaising with the data protection authority re the practical side of Safe Harbor adherence and call centre operation; (iii) advising the client on various regulatory matters, such as the profiling requirements under the draft EU Data Protection Regulation, permitted use of social media videos, and government surveillance rights; (iii) advising the client in a software use audit; (iv) assessing the feasibility of cloud services in the healthcare sector and in the public sector, (v) preparing various template agreements, data privacy / cloud / used software information materials; (vi) localising a CEE public procurement training deck and a client facing marketing guidance; and (vii) advising the client re the interpretation of the ECJ's "right to be forgotten" judgment.
  • Magyar Telekom on the establishment of a major e-health system (patient-doctor-pharmaceutical company communications platform), including detailed analysis on the data privacy aspects, preparing the contractual background and the data privacy consents, negotiations with the infrastructure service provider and liaising with the Data Protection Supervisory Authority.
  • British Telecom on the local data privacy requirements and VAT / archiving law aspects of the transfer of personal data from CEE into an integrated database. The tasks included preparing the required data privacy consents, employee and third party communications and making the necessary submissions for various tax and data privacy authorities. Countries involved: Czech Republic, Slovakia, Poland, Hungary, Russia and Ukraine, and also reviewing the various governmental access rights.
  • Canon on the review of its business, HR and employees guides on data privacy, adapting these guides in accordance with data transfer requirements under the local laws of the following countries: Bulgaria, Czech Republic, Hungary, Poland, Slovakia and Slovenia.
  • GE on the data privacy aspects of access to / transfer of the employee emails and the files stored by the employee in case of integrity/compliance offences and business continuity cases. Countries involved: United Kingdom, Germany, France, Italy, Poland, and Turkiye.
  • Johnson & Johnson on a data privacy audit regarding the operations of the Consumer and the MD&D business lines. Advised on its day-to-day data protection and privacy questions.
  • A major Hungarian bank on the contracting and regulatory aspects of obtaining Microsoft’s cloud computing services, (with specific focus on the practice and guidance of the Hungarian Financial Supervisory Authority, the Hungarian National Authority for Data Protection and Freedom of Information and the Article 29 Working Party, the Independent European data protection consulting firm, in cooperation with the European Commission).
  • Samsung Electronics on its day-to-day data protection and privacy questions.
  • A Hungarian low cost airline in 34 jurisdictions - following an ICO investigation - on the data protection requirements re its ticket agents, such as registrations, privacy policy amendments, data processing agreements and data retention requirements. Coordinating the registration procedures.
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Memberships & Roles

  • Founding member of the Data Protection Board of the Direct and Interactive Marketing Association
  • Member, Budapest Bar Association
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Publications

  • Navigating Out of Safe Harbors - CEE Legal Matters
  • Recent EU judgments in privacy cause far reaching implications on online operations - Financier Worldwide
  • Hungary develops its national public eHealth system - eHealth Law & Policy
  • Examining the impact of Weltimmo on e-commerce activities - Data Protection Law & Policy
  • The mandatory content of data processing information and regulations – detailed recommendations by the Hungarian National Authority for Data Protection and Freedom of Information (NAIH) to companies to facilitate compliance with the Information Act (article in Hungarian) - Jogifórum
  • The Act on data protection can be also applied to companies registered in a foreign country (article in Hungarian) - Origo
  • Hungarian DPA Reinvents Privacy Notices and Policies - The Privacy Advisor
  • Latest Hungarian reforms to protect state-owned operator - World Online Gambling Law Report
  • Data Protection Act Amendments Include Rules on BCRs, Data Breaches - World Data Protection Report
  • Data subject access to CCTV recordings (article in Hungarian) – Origo
  • Hungary - DPA Requesting a Flyby - Europe Data Protection Digest / The Privacy Advisor
  • BCRs, security breaches and increased fines on the horizon - a proposed bill to modify the Hungarian Data Protection Act - Data Protection Law & Policy
  • EU Data Protection Regulation – Let’s Start Preparing (article in Hungarian) – Kreativ Online
  • Hungary Steps Up its Child Protection Measures Online - Data Protection Law & Policy
  • Hungarian DPA Cracks Down on Fortune Telling Company's Direct Marketing, Here's What You Need To Know – The Privacy Advisor
  • CMS: Data Controllers to Revise their Practices 1-2 (article in Hungarian) – Origo
  • Updated Data Processing Practices – Recent findings from the DPA on Direct Marketing (article in Hungarian) – Jogifórum
  • 2014: Key Year in Data Protection (article in Hungarian) – Napi Gazdaság
  • Hungarian DPA Suggests Refinements in IT Policies – The Privacy Adivsor
  • CMS: 2014 – New Target Date of the EU’s Data Protection Reform (article in Hungarian) – Origo
  • DPA Sets Out New Guidelines for Data Processing Agreements - World Data Protection Report
  • "We've got a guy who wants to talk, but he's constrained." – Whistleblowing Rules in the Private Sector (article in Hungarian) – Jogifórum
  • CMS: The Employee may Report Unlawful Practices in a More Secure Way (article in Hungarian) – Origo
  • New Whistle-Blowing Law Introduces New Personal Data Protection Rules - World Data Protection Report
  • New Whistleblowing Law Generates New Data Privacy Issues in Hungary – The Privacy Advisor
  • Highlights from the New DPA’s “Year One” – The Privacy Advisor
  • EU Data Protection Law – Important Changes for Companies and Authorities (1-2) (article in Hungarian) – Origo
  • "Keep bangin' on the wall of Fortress Europe" The Draft EU Data Protection Regulation (article in Hungarian) – Jogifórum
  • Cloud computing – Challenges for the Financial Players (article in Hungarian) – Tanácsadó Magazin
  • FATCA – Financial and Insurance Law Challenges from the USA (article in Hungarian) – Napi Gazdaság
  • Cookie Monster is here! Cookies and the Law – Jogifórum
  • Cloud Computing and the Law (article in Hungarian) – Napi Gazdaság
  • Data Security UK style – Cases at the ICO (article in Hungarian) – Jogifórum
  • Financial Supervisory Authority issues Circular for Hungarian Financial Institutions on the Use of Cloud Computing Technologies – The Privacy Advisor
  • Hungary – European Commission Investigates the Independence of New Data Protection Authority – The Privacy Advisor
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Lectures list

  • April 2016 - Bring Your Own Device – Own Devices, Shared Protection - Microsoft “Cloud Seminar – Standards, Own Devices and Legal Compliance”
  • March 2016 - The New EU Data Protection Regulation and how it affects the tasks and liabilities of companies - Management Training Centre 5th Data Protection Conference
  • January 2016 - IoT / e-commerce sector in CEE – the current state of play, trends, challenges and opportunities - Mega Mission 2016: Explore business opportunities in IoT/e-commerce in CEE
  • May 2015 - Hybrid Cloud Computing Services – Practical Tips for Contract Drafting - Microsoft – „How to Provide Top-notch Monthly IT Services?”
  • 2014-2016 - Several presentation on data protection, including cloud computing, big data, etc. - Direct Interactive Marketing Federation
  • 2014-2015 - New Data Privacy Rules for SMEs in the EU - Direct- and personal marketing, SME case studies – Fejér, Baranya, Csongrád County Chambers of Commerce
  • November 2014 - E-health – Regulatory Trends in Europe - Infotér Conference 
  • October 2014 - Big Data and Data Driven Economy in the EU - HVG Conference & Seminar – Big data in the Marketing
  • November 2013 - Smart Metering and Smart Laws - Infotér Conference
  • June 2013 - Big Data – Legal Issues in the Public Sector - Parliament of the Information Society
  • November 2012 - Regulating the Cloud - Internet Hungary
  • October 2012 - Cloud Computing in the Public Sector - Infotér Conference
  • June 2012 - Cloud Computing: Expectations and Concerns - Challenges in the cloud – Cloud Computing and Data Privacy, Legal Forum conference
  • May 2011 - Hot Topics in the Hungarian Data Protection Law and Practice – 2011 - DataGuidance – International Association of Privacy Professionals - 5th Annual European Data Protection Intensive
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Education

  • 2012 - LL.M. in U.S. and Global Business Law, Suffolk University, Law School, Hungary
  • 2007 - Postgraduate degree in Infocommunications Law and Technology, University of Pécs, Hungary
  • 2003 - Post-graduate degree in International Trade Law, University of European Studies, Italy
  • 2004 - Degree in Law, Eötvös Loránd University, Hungary
  • 2004 - Degree in Media Studies, University of Szeged, Hungary
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Feed

31/03/2023
Di­git­isa­tion: cur­rent reg­u­lat­ory ini­ti­at­ives in the EU and Hun­gary
CMS Bud­apest will be host­ing again a new series of ac­cred­it­a­tion con­fer­ences ap­proved by the Hun­gari­an Bar As­so­ci­ation as part of the com­puls­ory ac­cred­it­a­tion sys­tem in Hun­gary.  Di­git­isa­tion: cur­rent...
04/01/2023
EU ad­opts NIS2 Dir­ect­ive to en­hance cy­ber­se­cur­ity and re­si­li­ence
The NIS2 will provide the frame­work for cy­ber­se­cur­ity risk man­age­ment meas­ures and re­port­ing ob­lig­a­tions in spe­cified sec­tors, such as en­ergy, trans­port, health, and di­git­al in­fra­struc­ture. Fur­ther­more...
21/11/2022
Hun­gary's pri­vacy de­cision on dir­ect mar­ket­ing asks: how much con­sent is...
In de­cision No. NAIH-2501-10/2022 of 12 Septem­ber 2022, the Hun­gari­an Data Pro­tec­tion and Free­dom of In­form­a­tion Au­thor­ity (NAIH) im­posed a HUF 30 mil­lion (EUR 74,500) data pro­tec­tion fine on Mag­yar Éremkiboc­sátó...
27/10/2022
European data board re­com­mends re­form­ing leg­al frame­work for in­tro­duc­tion...
On 10 Oc­to­ber 2022, the European Data Pro­tec­tion Board (EDPB) ad­op­ted a state­ment on the design choices for a di­git­al euro from the pri­vacy and data pro­tec­tion per­spect­ive, stat­ing that its shares the...
12/10/2022
Com­mis­sion pro­poses land­mark new rules on li­ab­il­ity for AI sys­tems
On 28 Septem­ber 2022, the European Com­mis­sion pro­posed the draft AI Li­ab­il­ity Dir­ect­ive (AILD Draft) on ad­apt­ing non-con­trac­tu­al civil li­ab­il­ity rules to ar­ti­fi­cial in­tel­li­gence as a po­ten­tial solu­tion...
27/10/2022
Sixth Wo­men in AI – Hun­gary (event)
Ar­ti­fi­cial in­tel­li­gence has had a sig­ni­fic­ant im­pact on the strength­en­ing and trans­form­a­tion of in­dus­tries all over the world. As we go deep­er in­to a di­git­ally altered so­ci­ety, ar­ti­fi­cial in­tel­li­gence...
27/09/2022
European Com­mis­sion pro­poses new Cy­ber Re­si­li­ence Act
On 15 Septem­ber 2022, the European Com­mis­sion pub­lished its pro­pos­al for a reg­u­la­tion on ho­ri­zont­al cy­ber­se­cur­ity re­quire­ments for products with di­git­al ele­ments. This draft of the Cy­ber Re­si­li­ence Act...
18/11/2022
Leg­al is­sues in the meta­verse
CMS Bud­apest is host­ing a new series of ac­cred­it­a­tion train­ing events ap­proved by the Hun­gari­an Bar As­so­ci­ation as part of the new com­puls­ory ac­cred­it­a­tion sys­tem in Hun­gary.  Leg­al is­sues in the meta­verse...
02/08/2022
Leg­al is­sues in the meta­verse / Part 4 - Ex­pec­ted im­pact of the EU Ar­ti­fi­cial...
Part 4 - Ex­pec­ted im­pact of the EU Ar­ti­fi­cial In­tel­li­gence Reg­u­la­tion, the meta­verse as a work­place In our first art­icle, we ex­amined the nature of the meta­verse, the shared vir­tu­al world. The emer­gence...
27/07/2022
Leg­al is­sues in the meta­verse / Part 3 - Data pro­tec­tion chal­lenges, the...
Part 3 - Data pro­tec­tion chal­lenges, the im­port­ance of cy­ber­se­cur­ity, ad­vert­ising reg­u­la­tion in the meta­verse In our first art­icle, we ex­amined the nature of the meta­verse, the shared vir­tu­al world...
19/07/2022
Leg­al is­sues in the meta­verse / Part 2 - Trade­marks and copy­right, NFTs...
Part 2 - Trade­marks and copy­right, NFTs and civil law prin­ciples in the meta­verse In our first art­icle, we ex­amined the nature of the meta­verse, the shared vir­tu­al world. In the meta­verse, trade in vir­tu­al...
14/07/2022
Leg­al is­sues in the meta­verse
In­tro­duc­tion to the meta­verse In re­cent months, ‘meta­verse’ has be­come a buzzword, fea­tured in nu­mer­ous art­icles and me­dia re­ports, and has even been re­ferred to as web 3.0, without a pre­cise defin­i­tion of what meta­verse is be­ing offered. However, the term is not new: it already ex­is­ted in the 1990s, and in the 2000s com­puter games be­came wide­spread, in which users could live a second life with their avatars, buy vir­tu­al ob­jects, ter­rit­or­ies and even ad­vert­ising space, in a vir­tu­al world built for this pur­pose. Block­chain tech­no­logy has giv­en a fur­ther boost to these de­vel­op­ments, mak­ing it pos­sible to add value to vir­tu­al goods through token­isa­tion and to link the world of cryp­tos to these vir­tu­al worlds, al­low­ing for real-time ex­change and man­age­ment of goods with real eco­nom­ic value. Leg­al is­sues in the meta­verse There are a vari­ety of leg­al is­sues con­cern­ing the meta­verse, es­pe­cially giv­en that it is a meet­ing point for mul­tiple tech­no­lo­gies, re­quir­ing or linked to serv­ers, host­ing, soft­ware, plat­forms, hard­ware and oth­er peri­pher­als (e.g. VR glasses and haptic gloves for sens­ing vir­tu­al ob­jects), con­tent, graph­ics, maps, build­ings, pho­tos, in­ter­faces, as well as block­chain for ac­quir­ing and re­gis­ter­ing token­ised vir­tu­al as­sets. This di­versity also raises a host of leg­al is­sues ran­ging from in­tel­lec­tu­al prop­erty rights to data pro­tec­tion and civil law.In this series of art­icles, we ex­plore the key is­sues con­cern­ing the meta­verse, in­clud­ing:Part 1: What is the meta­verse?Part 2: Trade­marks and copy­right, NFTs and civil law prin­ciples in meta­verseP­art 3: Data pro­tec­tion chal­lenges, the im­port­ance of cy­ber­se­cur­ity, ad­vert­ising reg­u­la­tion in meta­verseP­art 4: Ex­pec­ted im­pact of the EU Ar­ti­fi­cial In­tel­li­gence Reg­u­la­tion, the meta­verse as a work­place