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.

Threshold for submitting a relevant and reasoned objection (RROs) is very high

Article(s) involved (national, EU, or other): Article 60 GDPR


As a CSA it might be very difficult to substantially reason an objection (especially when a CSA is not well informed about the case early on in the procedure by the LSA). Often CSAs then tend to submit comments, rather than RROs, or they merely submit an objection during ‘informal consultation’. This clearly does not lead to the required peer pressure among SAs, as those SAs can ignore informal consultation or comments. Such decisions will, hence, also never end up at the EDPB dispute resolution mechanism. 

Ideal Solution

The text should ensure that the LSA cannot simply ignore other views, comments and exchanges on the draft decisions, besides RROs. 

Proposed Solution

Concept 8 (defining Article 60 further) and Concept 16 (definitions) could deal with this matter.

National Issues

National Issues