What’s the European Commission’s initiative about?
Especially targeting cross-border cases, the Commission’s initiative is focusing on streamlining the cooperation between national data protection authorities when it comes to the enforcement of GDPR.
What’s our approach and what do we comment on?
While we consider that improving cooperation between national data protection supervisory authorities when enforcing the GDPR in cross-border cases is essential to ensure a harmonized and thus efficient and effective robust enforcement, we would like to draw the attention of the European Commission to the importance of considering other dimensions of the GDPR enforcement mechanism in addition to Article 63 GDPR.
Against that background, our feedback revolves around two main aspects:
First, we are underlining the added value of complementary enforcement tools, such as those established by codes of conduct and monitoring bodies in the context of Articles 40 and 41 GDPR. Codes of conduct, especially when those bear a transnational scope, i.e., covering processing activities across several member states, can effectively support addressing pressing challenges such as the uniform application of GDPR requirements and consistent enforcement.
Second, given that those tools provide a significant added value when it comes to supporting GDPR enforcement, we would like to emphasize that the operationalization of such tools is still facing procedural obstacles. Further streamlining of approval and accreditation procedures under Article 40 and 41 GDPR is highly welcomed in that area.
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