<h3>Innovation-Friendly Adoption of AI Convention Rather Than a «Swiss AI Act»</h3>
<p>The Swiss Federal Council decided on February 12, 2025 that it does not support the implementation of broad, horizontal AI regulation in Switzerland. Thus, there will be no proposal for a «Swiss AI Act» or similar equivalent to the EU&#8217;s comprehensive AI Act (see our <a href="https://www.homburger.ch/de/insights/eu-ai-act-enters-into-force-on-august-1-2024">Bulletin</a> of July 16, 2024 for details on the EU AI Act).</p>
<p>Instead, the Swiss Federal Council prefers to implement the Council of Europe&#8217;s <a href="https://www.coe.int/en/web/artificial-intelligence/the-framework-convention-on-artificial-intelligence">AI Convention</a> by making limited sector-specific adjustments to existing laws and limiting general, cross-sector regulation to key areas relevant to fundamental rights, such as data protection. According to the Swiss Federal Council, the Swiss regulatory approach to AI shall be based on three objectives: strengthening Switzerland as a location for innovation, ensuring the protection of fundamental rights, including economic freedom, and increasing public trust in AI. Another important focus is to ensure the compatibility of the Swiss regulatory approach with the regulations of its main trading partners, in particular the EU. The aim is to avoid any «Swiss finish», <em>i.e.</em>, additional regulatory burdens on Swiss companies compared to market players in the EU.</p>
<h3>Outcome of the Review of the AI Regulatory Regime in Switzerland</h3>
<p>The decision of the Swiss Federal Council is based on an in-depth analysis commissioned by the Federal Council on November 22, 2023 (see our <a href="https://www.homburger.ch/de/insights/swiss-federal-council-launches-ai-regulatory-regime-review">Bulletin</a> of November 23, 2023). The objective of the analysis was to identify the need for regulatory action and to provide a basis for decision-making regarding the future shape of Swiss AI regulation. It was <a href="https://www.bakom.admin.ch/bakom/en/homepage/digital-switzerland-and-internet/strategie-digitale-schweiz/ai.html">published</a> on February 12, 2025.</p>
<p>A particular focus of the analysis was to examine the potential impact of ratifying the AI Convention. According to the analysis, Swiss law already contains legal norms applicable to AI, which would allow a partial adoption of the AI Convention. However, for a full adoption, additions are necessary, in particular to improve the transparency of AI systems, to assess their impact on fundamental rights and to ensure control mechanisms. The Swiss Federal Council has decided to prioritize sector-specific regulations and to introduce cross-sectoral regulations only where necessary.</p>
<h3>What is the AI Convention of the Council of Europe?</h3>
<p>The AI Convention is an international framework agreement to ensure that AI systems respect human rights, democracy and the rule of law throughout their life cycle, from design to decommissioning. It requires ratifying states to adopt legal and administrative measures to ensure ethical, transparent and non-discriminatory AI. At the same time, it promotes innovation under safe conditions and establishes international cooperation and monitoring mechanisms. The Convention does not regulate AI as such; it only addresses aspects of AI that relate to the protected interests mentioned above. It is also important to note that the AI Convention itself does not prescribe specific prohibitions, but requires ratifying states to assess whether specific regulation is necessary.</p>
<h3>What Are the Next Steps?</h3>
<p>The Swiss Federal Council has asked the federal administration, led by the Federal Department of Justice and Police to draft a proposal to incorporate the AI Convention into Swiss law. The draft should be available for public consultation by the end of 2026.</p>
<p>In addition to legislative measures, non-binding legal measures will be developed. These include self-declaration agreements and industry-specific solutions that provide greater flexibility for companies.</p>
<h3>Which Regulatory Changes Are to be Anticipated?</h3>
<p>The Federal Council has not yet decided which specific regulatory changes it will submit to parliament. However, it is generally expected that the proposal will include stricter transparency requirements, mandatory labeling of AI-generated content, and regulations governing political advertising on social media. In addition, data protection law may be revised, in particular to prevent AI-driven surveillance, such as facial recognition, or with regard to information obligations. In addition, the obligation to conduct a privacy impact assessment may be extended, with differentiated obligations for different stakeholders. Equality and non-discrimination issues are also expected to be addressed. Targeted rules are expected to be proposed for key sectors, including finance, healthcare and digital platforms.</p>
<h3>What is the Impact on Swiss Businesses?</h3>
<p>The Federal Council&#8217;s strategy aims to strengthen the regulation of AI risks without imposing excessive regulatory burdens on Swiss companies. This innovation-friendly strategy can enable flexible solutions for companies and strengthen Switzerland&#8217;s position as a leading hub for AI development and applications. It remains to be seen, however, what specific legislative changes will be proposed and to what extent such proposals will become law in Switzerland.</p>


Homburger Bulletin

Swiss AI Regulation: Tailored Rules Instead of a Swiss AI Act

<h3>As from September 15, 2024, the New Framework will Facilitate the Disclosure of Personal Data from Switzerland to the U.S.</h3>
<h3>What Is New?</h3>
<p>By way of its decision of August 14, 2024, the Swiss Federal Council has recognized that the Swiss-U.S. DPF provides for an adequate level of data protection when private companies or public authorities in Switzerland disclose personal data to U.S. companies that participate in the Swiss-U.S. DPF. <a href="https://www.fedlex.admin.ch/eli/cc/2022/568/en#annex_1" target="_blank" rel="noopener">Annex 1</a> of the Swiss Federal Ordinance on Data Protection will be updated to include such disclosures under the Swiss-U.S. DPF as guaranteeing an adequate level of data protection.</p>
<p>Switzerland thus follows the approach taken earlier by the EU with the adoption of the EU-U.S. Data Privacy Framework (<strong>EU-U.S. DPF</strong>) (see our <a href="https://www.homburger.ch/en/insights/are-data-transfers-to-the-united-states-safe-again" target="_blank" rel="noopener">Bulletin of July 11, 2023</a>). The new Swiss-U.S. DPF substantially corresponds to the EU-U.S. DPF, which marked the (preliminary) end of a period of uncertainty for disclosures of personal data to the U.S. after the «Schrems II» landmark decision of the Court of Justice of the European Union (<strong>CJEU</strong>) struck down the predecessor of the EU-U.S. DPF (see our <a href="https://homburger.ch/de/insights/eugh-urteil-im-fall-schrems-ii" target="_blank" rel="noopener">Bulletin of July 16, 2020</a>).</p>
<p>Most importantly, the Swiss-U.S. DPF provides for the following:</p>
<ul>
<li>The U.S. aligns its legal system with fundamental principles of Swiss law by way of the <a href="https://www.federalregister.gov/documents/2022/10/14/2022-22531/enhancing-safeguards-for-united-states-signals-intelligence-activities" target="_blank" rel="noopener">U.S. Executive Order 14086</a> executed by President Biden on October 7, 2022 (<strong>EO 14086</strong>). The changes include a limitation of U.S. intelligence activities to what is proportionate, oversight of U.S. intelligence services, and effective redress. Earlier this year on June 13, 2024, the <a href="https://www.justice.gov/opcl/executive-order-14086" target="_blank" rel="noopener">U.S. Attorney General has designated Switzerland as a qualifying state</a> for purposes of implementing the redress mechanism.</li>
<li>U.S. companies may self-certify that they adhere to a defined set of privacy principles. Certified U.S. companies must ensure in particular the rights for data subjects as known from the DPA and redress options, including a free of charge independent dispute resolution mechanism and an arbitration panel. Compliance with these principles is monitored by the U.S. Department of Commerce (<strong>DoC</strong>) and enforced by the U.S. Federal Trade Commission.</li>
</ul>
<h3>When Will the Swiss-U.S. DPF Enter Into Force?</h3>
<p>The new Swiss-U.S. DPF will be effective from September 15, 2024.</p>
<h3>What Are the Consequences of the New Swiss-U.S. DPF?</h3>
<p>The Swiss-U.S. DPF will facilitate disclosures of personal data from Switzerland to the U.S.: Once effective, Swiss data exporters will be able to disclose personal data to recipients in the U.S. who participate in the Swiss-U.S. DPF without having to enter into SCC and performing a data transfer impact assessment.</p>
<p>Even for companies continuing to rely on SCC, the new Swiss-U.S. DPF will facilitate their data disclosure to the U.S. and the data transfer impact assessment, given that the limitations imposed by the U.S. EO 14086 apply irrespective of whether personal data is disclosed under the Swiss-U.S. DPF or based on a different transfer instrument, such as the SCC.</p>
<h3>Is There a List of U.S. Companies Participating in the Swiss-U.S. DPF?</h3>
<p>The DoC maintains and publishes a list of U.S. companies that have self-certified and declared to comply with the Swiss-U.S. DPF (<strong>DPF List</strong>, accessible <a href="https://www.dataprivacyframework.gov/list" target="_blank" rel="noopener">here</a>). There are exceptions as to which U.S. companies are eligible to participate in the Swiss-U.S. DPF, but Swiss data exporters can rely on the fact that companies on the list published by the DoC are certified.</p>
<h3>Is There Still a Need to Execute a Data Transfer Agreement Under the Swiss-U.S. DPF?</h3>
<p>Even when disclosing personal data under the Swiss-U.S. DPF, it is typically advisable for data exporters to enter into a suitable data transfer agreement with the data importer. This agreement should include the following, in addition to any other terms governing the relevant data disclosure in the specific circumstances:</p>
<ul>
<li>Obligation to comply with the principles of the Swiss-U.S. DPF;</li>
<li>Obligation to remain duly certified under the Swiss-U.S. DPF;</li>
<li>Obligation to notify data exporter immediately of a removal of the DPF List and the reason for such removal;</li>
<li>Mechanism to tackle the consequences of a removal from the DPF List.</li>
</ul>
<h3>What to Do with Existing SCC or Binding Corporate Rules?</h3>
<p>In principle, SCC or binding corporate rules that were concluded earlier are no longer necessary for data disclosures to a U.S. data importer who participates in the Swiss-U.S. DPF. Companies should however carefully consider whether to fully migrate their disclosures of personal data to the U.S. to the Swiss-U.S. DPF as there may be valid reasons to continue relying on the SCC or binding corporate rules:</p>
<ul>
<li>If the U.S. data importer is removed from the DPF List, the data disclosure is no longer considered to be covered by an adequate level of protection. Existing SCC or binding corporate rules could still serve as a fallback to ensure adequate protection; and</li>
<li>The validity of the EU-U.S. DPF is already being challenged through lawsuits in the EU, as its predecessors were. Should the CJEU ultimately decide to invalidate the EU-U.S. DPF, this will in all likelihood also impact the Swiss-U.S. DPF and companies relying exclusively on the Swiss-U.S. DPF may be left unprotected. Thus, maintaining existing SCC or binding corporate rules may serve as a protection should the Swiss-U.S. DPF be invalidated at some point.</li>
</ul>
<h3>What Are the Consequences of a Removal from the DPF List?</h3>
<p>U.S. companies may fall off the DPF List of participating companies if:</p>
<ul>
<li>They voluntarily withdraw from the Swiss-U.S. DPF;</li>
<li>They fail to complete their annual re-certification; or</li>
<li>They persistently fail to comply with the principles.</li>
</ul>
<p>For data disclosures that occurred <em>prior</em> to the removal of the U.S. company from the DPF List, the Swiss data exporter may argue that these disclosures were made lawfully under the adequacy decision.</p>
<p>For data disclosures that occurred <em>after</em> the removal of the U.S. company from the DPF List, the Swiss Federal Council’s adequacy decision does not apply. Instead, the parties must guarantee an adequate level of data protection by other means recognized by the law, including SCC or binding corporate rules. If no such guarantees can be put in place, the U.S. data importer should return or delete the personal data.</p>
<h3>Is the Swiss-U.S. DPF a Permanent Solution for Swiss-U.S. Data Disclosures?</h3>
<p>In principle, the Swiss-U.S. DPF is intended to be a permanent solution. However, it marks the third attempt of Swiss and U.S. authorities to facilitate transatlantic disclosure of personal data, after the CJEU struck down first the EU-U.S. Safe Harbor Framework, and then the EU-U.S. Privacy Shield (with the so-called «Schrems II» decision, see our <a href="https://www.homburger.ch/en/insights/cjeu-decision-schrems-ii-new-hurdles-data-transfers-usa" target="_blank" rel="noopener">Bulletin of July 16, 2020</a>), which in each case also ended the corresponding arrangements between Switzerland and the U.S. Given that the EU-U.S. DPF is already being challenged through lawsuits in the EU, time will tell whether the EU-U.S. DPF and the Swiss-U.S. DPF will withstand the judicial review.</p>
<p>In addition, the U.S. legislation may change. The Swiss Federal Council will constantly monitor the relevant U.S. decisions and review the adequacy decision on a regular basis. The first review will take place one year from now. If the Swiss-U.S. DPF malfunctions, the adequacy decision will be adjusted or withdrawn.</p>


RZ_Preview_Lock_SB_01

New Swiss-U.S. Data Privacy Framework

<p>On January 15, 2024, the EU Commission published its <a href="https://ec.europa.eu/commission/presscorner/detail/en/ip_24_161" target="_blank" rel="noopener">report</a> on the results of its first review of the adequacy decisions previously taken under the old EU Data Protection Directive. The EU Commission concludes that <strong>Switzerland continues to provide an adequate level of protection for personal data</strong> transferred from the EU.</p>
<p>According to its report, the EU Commission welcomes the developments in the Swiss legal framework since the adoption of the first adequacy decision in July 2000, including in particular the modernization of the Swiss Data Protection Act (cf. our <a href="https://www.homburger.ch/en/insights/revision-of-the-swiss-data-protection-law-is-complete" target="_blank" rel="noopener">Bulletin</a> of August 31, 2022). These developments have contributed to an increased level of data protection, in a manner sufficient for the EU Commission to maintain its adequacy decision.</p>
<p>Maintaining the EU adequacy decision was one of the main objectives of the revision of the Swiss Data Protection Act, which entered into force on September 1, 2023: Without the EU&#8217;s recognition of the adequacy of Swiss data protection law, the export of personal data from the EU to Switzerland would have become much more burdensome. Today&#8217;s confirmation by the EU Commission thus marks the achievement of a key goal in the efforts to modernize Swiss data protection law in a manner consistent with the EU General Data Protection Regulation (GDPR).</p>
<p>The review of adequacy decisions by the EU Commission, which has now been completed, is the first such review since the GDPR came into force in 2018. The GDPR calls for regular reviews, and the EU underlines its intention to further intensify dialogue and cooperation with like-minded international partners on data flows and digital issues in general.</p>


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20250326 - Legal 500 Rankings 2025

The Legal 500 Rankings 2025: Homburger top ranked

<p>The Legal 500 has ranked Homburger Tier 1 in 13 categories and recognized us in an additional 9 practice areas: Banking and Finance; Capital Markets; Commercial, Corporate and M&amp;A; Competition; Construction; Data Privacy and Data Protection; Dispute Resolution: Arbitration; Dispute Resolution: Litigation; Employment; Fintech; Healthcare and Life Sciences; Insolvency and Corporate Recovery; Insurance; Intellectual Property; Private Client; Public Law; Real Estate; Regulatory, Compliance and Investigations; Sports Law; Tax; TMT and Transport.</p>
<p>Over all ranked categories, 52 of our lawyers achieved individual rankings: <a href="https://www.homburger.ch/en/team/alexander-wherlock" target="_blank" rel="noopener">Alexander Wherlock</a>, <a href="https://www.homburger.ch/en/team/allegra-arnold" target="_blank" rel="noopener">Allegra Arnold</a>, <a href="https://www.homburger.ch/en/team/andreas-burger" target="_blank" rel="noopener">Andreas Burger</a>, <a href="https://www.homburger.ch/en/team/andreas-muller" target="_blank" rel="noopener">Andreas Müller</a>, <a href="https://www.homburger.ch/en/team/andri-hess" target="_blank" rel="noopener">Andri Hess</a>, <a href="https://www.homburger.ch/en/team/angelika-murer" target="_blank" rel="noopener">Angelika Murer</a>, <a href="https://www.homburger.ch/en/team/anna-peter" target="_blank" rel="noopener">Anna Peter</a>, <a href="https://www.homburger.ch/en/team/balz-gross" target="_blank" rel="noopener">Balz Gross</a>, <a href="https://www.homburger.ch/en/team/benedikt-maurenbrecher" target="_blank" rel="noopener">Benedikt Maurenbrecher</a>, <a href="https://www.homburger.ch/en/team/benjamin-leisinger" target="_blank" rel="noopener">Benjamin Leisinger</a>, <a href="https://www.homburger.ch/en/team/claudia-suter" target="_blank" rel="noopener">Claudia Suter</a>, <a href="https://www.homburger.ch/en/team/claudio-bazzani" target="_blank" rel="noopener">Claudio Bazzani</a>, <a href="https://www.homburger.ch/en/team/daniel-daeniker" target="_blank" rel="noopener">Daniel Daeniker</a>, <a href="https://www.homburger.ch/en/team/daniel-haeberli" target="_blank" rel="noopener">Daniel Haeberli</a>, <a href="https://www.homburger.ch/en/team/daniel-hasler" target="_blank" rel="noopener">Daniel Hasler</a>, <a href="https://www.homburger.ch/en/team/daniel-hausermann" target="_blank" rel="noopener">Daniel Häusermann</a>, <a href="https://www.homburger.ch/en/team/david-oser" target="_blank" rel="noopener">David Oser</a>, <a href="https://www.homburger.ch/en/team/david-thomann" target="_blank" rel="noopener">David Thomann</a>, <a href="https://www.homburger.ch/en/team/dieter-gericke" target="_blank" rel="noopener">Dieter Gericke</a>, <a href="https://www.homburger.ch/en/team/dieter-grunblatt" target="_blank" rel="noopener">Dieter Grünblatt</a>, <a href="https://www.homburger.ch/en/team/dilber-devitre" target="_blank" rel="noopener">Dilber Devitre</a>, <a href="https://www.homburger.ch/en/team/fabrice-eckert" target="_blank" rel="noopener">Fabrice Eckert</a>, <a href="https://www.homburger.ch/en/team/felix-dasser" target="_blank" rel="noopener">Felix Dasser</a>, <a href="https://www.homburger.ch/en/team/flavio-romerio" target="_blank" rel="noopener">Flavio Romerio</a>, <a href="https://www.homburger.ch/en/team/frank-gerhard" target="_blank" rel="noopener">Frank Gerhard</a>, <a href="https://www.homburger.ch/en/team/franz-hoffet" target="_blank" rel="noopener">Franz Hoffet</a>, <a href="https://www.homburger.ch/en/team/gabrielle-nater-bass" target="_blank" rel="noopener">Gabrielle Nater-Bass</a>, <a href="https://www.homburger.ch/en/team/georg-rauber" target="_blank" rel="noopener">Georg Rauber</a>, <a href="https://www.homburger.ch/en/team/gregor-buhler" target="_blank" rel="noopener">Gregor Bühler</a>, <a href="https://www.homburger.ch/en/team/hansjurg-appenzeller" target="_blank" rel="noopener">Hansjürg Appenzeller</a>, <a href="https://www.homburger.ch/en/team/jeremy-reichlin" target="_blank" rel="noopener">Jeremy Reichlin</a>, <a href="https://www.homburger.ch/en/team/julian-schwaller" target="_blank" rel="noopener">Julian Schwaller</a>, <a href="https://www.homburger.ch/en/team/jurg-frick" target="_blank" rel="noopener">Jürg Frick</a>, <a href="https://www.homburger.ch/en/team/kirsten-wesiak-schmidt" target="_blank" rel="noopener">Kirsten Wesiak-Schmidt</a>, <a href="https://www.homburger.ch/en/team/laetitia-fracheboud" target="_blank" rel="noopener">Laetitia Fracheboud</a>, <a href="https://www.homburger.ch/en/team/luca-dal-molin" target="_blank" rel="noopener">Luca Dal Molin</a>, <a href="https://www.homburger.ch/en/team/marcel-dietrich" target="_blank" rel="noopener">Marcel Dietrich</a>, <a href="https://www.homburger.ch/en/team/mariella-orelli" target="_blank" rel="noopener">Mariella Orelli</a>, <a href="https://www.homburger.ch/en/team/miguel-sogo" target="_blank" rel="noopener">Miguel Sogo</a>, <a href="https://www.homburger.ch/en/team/philippe-baumann" target="_blank" rel="noopener">Philippe Baumann</a>, <a href="https://www.homburger.ch/en/team/rene-bosch" target="_blank" rel="noopener">René Bösch</a>, <a href="https://www.homburger.ch/en/team/reto-heuberger" target="_blank" rel="noopener">Reto Heuberger</a>, <a href="https://www.homburger.ch/en/team/richard-stauber" target="_blank" rel="noopener">Richard Stäuber</a>, <a href="https://www.homburger.ch/en/team/roman-baechler" target="_blank" rel="noopener">Roman Baechler</a>, <a href="https://www.homburger.ch/en/team/stefan-bindschedler" target="_blank" rel="noopener">Stefan Bindschedler</a>, <a href="https://www.homburger.ch/en/team/stefan-blunschi" target="_blank" rel="noopener">Stefan Blunschi</a>, <a href="https://www.homburger.ch/en/team/stefan-gaumann" target="_blank" rel="noopener">Stefan Gäumann</a>, <a href="https://www.homburger.ch/en/team/stefan-kramer" target="_blank" rel="noopener">Stefan Kramer</a>, <a href="https://www.homburger.ch/en/team/stefan-oesterhelt" target="_blank" rel="noopener">Stefan Oesterhelt</a>, <a href="https://www.homburger.ch/en/team/stefanie-pfisterer" target="_blank" rel="noopener">Stefanie Pfisterer</a>, <a href="https://www.homburger.ch/en/team/tanja-niederer" target="_blank" rel="noopener">Tanja Niederer</a>, <a href="https://www.homburger.ch/en/team/tobias-kaufmann" target="_blank" rel="noopener">Tobias Kaufmann</a>.</p>
<p>The Legal 500 as a part of Legalease, a provider of legal market information, analyses the capabilities of law firms across the world and publishes annual rankings based upon extensive research.</p>


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Candence Design Systems Inc. aquires BETA CAE Systems

Homburger advises Cadence on its  USD 1.24 bn acquisition of BETA CAE Systems

<p>On March 5, 2024, Cadence Design Systems Inc. (Nasdaq: CDNS), a leading global EDA and Intelligent System Design provider, announced that it has signed a definitive agreement to acquire BETA CAE Systems International AG, a leading provider of multi-domain, engineering simulation solutions headquartered in Switzerland.</p>
<p>Under the terms of the definitive agreement, Cadence will pay approximately USD 1.24 bn for the transaction, with 60 percent of the consideration to be paid in cash and 40 percent to be paid through the issuance of Cadence common stock to current BETA CAE shareholders. The transaction, which is subject to customary conditions, is expected to close in the second quarter of this year.</p>
<p>Homburger advises Cadence Design Systems Inc. on the Swiss aspects of the transaction. The Homburger team is led by Daniel Hasler and includes Léonard Aeschlimann, Bianca Nedwed, Daniel Bötticher, Paula Delissen and Luc Huber (all Corporate / M&amp;A), Gregor Bühler and Kimberly Amrein (both Employment and Executive Compensation), Kirsten Wesiak-Schmidt and Marc Wang (both IP / IT), Jonas Krull (Competition, Regulatory), as well as Peter Müller (Tax).</p>


Homburger advises Cadence on its USD 1.24 bn acquisition of BETA CAE Systems

HIG Capital

<p>On November 3, 2022, H.I.G. Capital, a leading global investment firm with USD 52 bn of equity capital under management, announced that one of its affiliates has completed the acquisition of Celerion Holdings Inc., a leading full-service provider of outsourced clinical research services to the pharmaceutical industry.</p>
<p>The Homburger team comprised partner Andreas Müller, lead associate Sarah Chevalley, associate Oliver Kneubühl and junior associate Michele Fazari (all Corporate / M&amp;A), associates Joel Fink (IP / IT) and Kirsten Wesiak-Schmidt (Data Protection).</p>


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The Legal 500 Rankings 2025: Homburger top ranked

Homburger advises Cadence on its USD 1.24 bn acquisition of BETA CAE Systems

Homburger advised H.I.G. Capital on its acquisition of Celerion

Swiss AI Regulation: Tailored Rules Instead of a Swiss AI Act

New Swiss-U.S. Data Privacy Framework

EU Confirms Adequacy of Swiss Data Protection Law

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The Legal 500 Rankings 2025: Homburger top ranked

Homburger advises Cadence on its USD 1.24 bn acquisition of BETA CAE Systems

Homburger advised H.I.G. Capital on its acquisition of Celerion

Swiss AI Regulation: Tailored Rules Instead of a Swiss AI Act

New Swiss-U.S. Data Privacy Framework

EU Confirms Adequacy of Swiss Data Protection Law

§8 Datenschutz bei Marketingaktivitäten

§5 Rechtsdurchsetzung durch den Eidgenössischen Datenschutz- und Öffentlichkeitsbeauftragten

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