In the past years we have identified more than 60 procedural issues that we have experienced first-hand in daily operations. We have summarized them on the page below. Many of these issues are symptoms of an underlying procedural problem.

Effective procedure – competence of the SA

Article(s) involved (national, EU, or other):


The absence of deadline regarding whether a SA considers itself competent delays the procedure (by contrast, Article 56(3) GDPR provides that when a case is transferred by an SA to a LSA, the latter has 3 weeks to confirm whether it will handle the case).

Ideal Solution

The text should provide such a deadline. The decision whether or not a SA considers itself competent should be subject to a deadline, i.e. within 3 months from the day of receipt of the complaint.

Proposed Solution

Concepts 9, 10, 14 and 16 should solve these issues.

Reference to specific noyb cases:

See google case from noyb at the CNIL which took more than 4 years to reach a conclusion on the LSA. The decision is not reached yet.

National Issues

National Issues