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Mark Young

Mark Young is an experienced tech regulatory lawyer and a vice-chair of Covington’s Data Privacy and Cybersecurity Practice Group. He advises major global companies on their most challenging data privacy compliance matters and investigations. Mark also leads on EMEA cybersecurity matters at the firm. In these contexts, he has worked closely with some of the world’s leading technology and life sciences companies and other multinationals.

Mark has been recognized for several years in Chambers UK as "a trusted adviser - practical, results-oriented and an expert in the field;" "fast, thorough and responsive;" "extremely pragmatic in advice on risk;" “provides thoughtful, strategic guidance and is a pleasure to work with;” has "great insight into the regulators;" and “is technologically sophisticated and advises on true issues of first impression, particularly in the field of AI."

Drawing on over 20 years of experience, Mark specializes in:

Providing practical guidance and advising on potential exposure under GDPR and international data privacy laws in relation to innovative products and services.
Handling complex regulatory investigations and enforcement actions involving data privacy regulators in the UK, EU and globally, and advising on follow-on litigation risk.
Helping clients respond to cybersecurity incidents, including ransomware, supply chain incidents, state-sponsored attacks, insider threats, personal data breaches, and IP and trade secret theft.
Advising various clients on the EU NIS2 Directive, Cyber Resilience Act (CRA), and other emerging EU, UK, and global cybersecurity laws and regulations.
Advising life sciences companies on industry-specific data privacy issues, including clinical trials, pharmacovigilance, and digital health products and services.
Advising on data privacy compliance in relation to employees and international transfers of data in connection with white collar investigations.
Providing strategic advice and advocacy on a range of UK and EU technology law reform issues relating to data privacy, cybersecurity, eIDs, and software.
Representing clients in connection with references to the Court of Justice of the EU.

Contact:Read more about Mark YoungEmail

On 20 January 2026, the European Commission published a proposal for a Regulation to update and replace the Cybersecurity Act (Regulation 2019/881). The proposal—known as the Cybersecurity Act 2 (CSA2)—forms part of a wider package aimed at modernizing and streamlining the EU’s cybersecurity framework and is closely linked to the Commission’s parallel proposal to amend Directive (EU) 2022/2555 (NIS2). We cover that proposal in a separate blog post.

CSA2 covers two main areas that will be relevant to private companies. First, it would introduce the EU’s first horizontal framework for ICT supply chain security—this is an entirely new addition that is not contained in the Cybersecurity Act, and could have significant implications for organizations in sectors that procure components from providers located in high-risk jurisdictions (e.g., telecoms). Second, it would update and expand the existing framework for cybersecurity certifications (the European Cybersecurity Certification Framework, or ECCF). In addition, it would significantly expand the role of the EU cybersecurity agency, ENISA.

Below, we summarize the main elements of the proposal.Continue Reading European Commission Proposes Cybersecurity Act 2: New EU Supply Chain Rules and Certification Reforms

On 20 January 2026, the European Commission published a proposal to amend the Directive (EU) 2022/2555 (NIS2) as part of a broader package to streamline the EU’s cybersecurity framework. The Commission also issued a proposal to revise the EU Cybersecurity Act (CSA2), which we cover in a separate blog post.

The proposed amendments build on earlier streamlining efforts in the Commission’s Digital Omnibus Package—published on 19 November 2025—which introduced the first wave of technical adjustments to NIS2. Those earlier amendments focused on creating a single framework for reporting cyber incidents and clarifying how NIS2 interacts with sectoral regimes such as the CER Directive and DORA.

With this proposal, the Commission now aims to clarify the scope of the law, harmonize technical measures, introduce certification‑based compliance pathways, and strengthen cross‑border supervision through an expanded role for ENISA.

Below, we summarize the main elements of the proposal and what they could mean for entities in scope of NIS2.Continue Reading European Commission Proposes Targeted Amendments to NIS2 to Simplify Compliance and Align With Proposed Cybersecurity Act 2

As the UK Government has recognized, cyber incidents—such as Jaguar Land Rover, Marks and Spencer, Royal Mail and the British Library—are costing UK businesses billions annually and causing severe disruption. The Government recognizes that cybersecurity is a critical enabler of economic growth (“we cannot have growth without stability”), and that the current laws have “fallen out of date and are insufficient to tackle the cyber threats faced by the UK.” Accordingly the UK Government this week published its long-awaited Cyber Security and Resilience Bill (the “Bill”), which will amend the existing Network and Information Systems Regulations 2018 (the “NIS Regulations”), and grant new powers to regulators and the Government in relation to cybersecurity.

The NIS Regulations are the UK’s pre-Brexit implementation of Directive (EU) 2016/1148 (the “NIS Directive”), which established a “horizontal” cybersecurity regulatory framework covering essential services in five sectors (transport, energy, drinking water, health, and digital infrastructure) and some digital services (online marketplaces, online search engines, and cloud computing services). EU legislators replaced NIS Directive in 2022 with the “NIS2” Directive, which Member States were meant to transpose into national law by October of last year (although many are still late in doing so. See our post on NIS2 here for an overview of the requirements of NIS2).

The Bill is the UK’s effort at modernizing the framework originally set out in the NIS Directive. In its current form, the Bill will:

  • Significantly expand the scope of the NIS Regulations—to cover, among other things, data centers and managed service providers—and impose additional substantive obligations on covered organizations.
  • Increase potential fines—up to GBP 17m or 4% of the worldwide turnover of an undertaking—and extend the powers of competent authorities to share information with one another, issue guidance, and take enforcement action.
  • Establish a framework for future changes to the NIS Regulations, mechanisms for competent authorities to impose specific cybersecurity requirements on covered organizations, and greater Government direction of cybersecurity matters.

Below, we set out further detail on five major changes in UK cybersecurity regulation arising from the Bill.Continue Reading Five major changes to the regulation of cybersecurity in the UK under the Cyber Security and Resilience Bill

The UK Information Commissioner’s Office (“ICO”) recently announced a new online tracking strategy, which aims to ensure a “fair and transparent online world where people are given meaningful control over how they are tracked online.”

Online advertising is one of the ICO’s current areas of strategic focus…

Continue Reading ICO announces its online tracking strategy for 2025

On 23 January 2025, we hosted the 2025 edition of the Covington European Life Sciences Symposium. The Symposium brought together colleagues from London, Brussels, Frankfurt and Dublin with our industry connections to explore the evolving challenges and opportunities facing the European life sciences sector.

Throughout the day our speakers shared their perspectives on a range of legal, regulatory, and business trends, including the evolving regulatory frameworks in the EU and UK; information exchange in ongoing collaboration; investigations and whistleblowing; key ESG topics, and the complexity of options to acquire in pharma deals.

We have set out some of the discussion from the sessions below.

European Life Sciences – The Changing Landscape for Pharma and Biotech

Grant Castle, Head of Covington’s European Life Sciences Regulatory Practice, Peter Bogaert, Marie Doyle-Rossie and Anna Wawrzyniak kicked off with a discussion about the Changing Landscape for Pharma and Biotech.

The UK and EU both aim to deliver access to innovative and transformative medicines and foster international competitiveness in the life sciences industry. Despite the practical challenges faced by the UK Medicines and Healthcare products Regulatory Agency (MHRA) in recent years, it has emerged as an ambitious regulator and is establishing innovative regulatory frameworks, including an international reliance scheme (see our update here), point of care manufacturing regulations, and the relaunch of the Innovative Licensing and Access Pathway (ILAP).

The EU is also pursuing a wave of legislative reform, including wide ranging revisions to the EU’s pharmaceutical legislation, the EU’s supplementary protection certificates (SPC) rules, and proposals for a compulsory licensing scheme.

There can sometimes be a tension between the UK’s and EU’s aims and the practical impacts of regulatory reform, especially in the early stages of implementation.Continue Reading The Covington European Life Sciences Symposium 2025

On 15 January 2025, the European Commission published an action plan on the cybersecurity of hospitals and healthcare providers (the “Action Plan”). The Action Plan sets out a series of EU-level actions that are intended to better protect the healthcare sector from cyber threats. The publication of the Action Plan follows a number of high-profile incidents in recent years where healthcare providers across the European Union have been the target of cyber attacks.

Whilst the Action Plan primarily focuses on healthcare providers including hospitals, clinics, care homes, rehabilitation centres and others, the plan identifies interdependence between those providers and the healthcare industry. Therefore, some of the measures proposed address risks affecting the broader healthcare supply chain and ecosystem, and will potentially have implications for pharmaceutical and biotechnology industry players as well as medical device manufacturers.

The action that will be of most significance for industry is the plan for Member States to request that entities subject to the NIS2 Directive, including healthcare organisations, must report on ransom payments when reporting significant incidents to the competent authority under the NIS2 Directive (section 3.3, p.14). The Action Plan rationalizes this proposal by stating that the collection of further data is needed to understand the effectiveness of measures taken against ransomware attacks, and noting that such reporting would support the effective investigation of incidents. Reporting of ransomware payments is not required by the NIS2 Directive, so this would represent a significant change for in-scope entities. While this is titled a ‘national action’ to be implemented by Q4 2025, it is not immediately clear from the Action Plan if the proposal would take the form of a new EU law that imposes the obligation on Member States or otherwise.Continue Reading European Commission Publishes Action Plan on Cybersecurity of Hospitals and Healthcare Providers

The UK Government has announced that it intends to introduce the Cyber Security and Resilience Bill (the “Bill”) to Parliament in 2025. Formally proposed as part of the King’s Speech in July, this Bill is intended to strengthen the UK’s cross-sectoral cyber security legislation to better protect the…

Continue Reading What to expect from the UK’s Cyber Security and Resilience Bill (and when)

Last month, the European Commission published a draft Implementing Regulation (“IR”) under the EU’s revised Network and Information Systems Directive (“NIS2”). The draft IR applies to entities in the digital infrastructure sector, ICT service management and digital service providers (e.g., cloud computing providers, electronic communications service providers, and online social networks). It sets out further detail on (i) the specific cybersecurity risk-management measures those entities must implement; and (ii) when an incident affecting those entities is considered to be “significant”. Once finalized, it will apply from October 18, 2024.

Many companies may be taken aback by the granular nature of some of the technical measures listed and the criteria to determine if an incident is significant and reportable – especially coming so close to the October deadline for Member States to start applying their national transpositions of NIS2.

The IR is open for feedback via the Commission’s Have Your Say portal until July 25.

  1. Cybersecurity risk-management measures

The Annex to the draft IR sets out further detail on the cybersecurity risk-management measures referred to in Article 21(2) of NIS2 that covered entities must implement.

As a general matter, the IR states that relevant entities should take a proportionate approach to applying these measures, and implement alternatives that achieve the same purpose if a specific measure is unsuitable (e.g., if a particular covered entity is small).Continue Reading NIS2: Commission Publishes Long-Awaited Draft Implementing Regulation On Technical And Methodological Requirements And Significant Incidents

Earlier this week, Members of the European Parliament (MEPs) cast their votes in favor of the much-anticipated AI Act. With 523 votes in favor, 46 votes against, and 49 abstentions, the vote is a culmination of an effort that began in April 2021, when the EU Commission first published its …

Continue Reading EU Parliament Adopts AI Act

Yesterday, the European Commission, Council and Parliament announced that they had reached an agreement on the text of the Cyber Resilience Act (“CRA”). As a result, the CRA now looks set to finish its journey through the EU legislative process early next year. As we explained in our prior…

Continue Reading The EU’s Cyber Resilience Act Has Now Been Agreed