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.

LSAs respond differently to RROs

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


Some LSAs submit a revised draft decision for a new round of consultation (as the GDPR requires), while other LSAs submit certain documents (such as composite memoranda) in which they respond to comments. Problematic for homogeneity in working practices.

Ideal Solution

The draft regulation should emphasize that a revised draft decision should be shared for a new round of consultation (including a deadline)

Proposed Solution

Concept 8 addresses this issue.

National Issues

National Issues