On 25th January 2012, the European Commission published a proposal that would comprehensively reform the European data protection legal regime. One aspect of the proposal, a new Regulation (the “Proposed Regulation”),1 would modernise and further harmonise the data protection regime created by the Data Protection Directive (95/46/EC). Another aspect of the Commission’s proposal, a new Directive (the “Proposed Directive”), would set out new rules on “the protection of individuals with…