On 25th January 2012, the European Commission published a proposal that would comprehensively reform the European data protection legal regime. One aspect of its 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(2) (the “Proposed Directive”), would set out new rules on “the protection of individuals with…