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.

Relevant information to share in the cooperation procedure

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


Article 60 does not define what should be shared with the other SAs (draft decision, complaints, submissions of the parties, attachments, evidence, inspection report, ..). The same is true about which documents must be shared with the parties in the context of the right to be heard.

Ideal Solution

The regulationshould clarify what documents should be at minimum shared in the cooperation procedure of Article 60 GDPR. The text should also clarify that these documents should be shared with the parties for them to exercise their right and provide for limited exceptions under which they are cannot receive the submission. 

Proposed Solution

Concepts 7 to 10 address this issue.

Reference to specific noyb cases:

See Irish case involving Meta where the Irish SA does not share all elements of the case with the other SAs and the EDPB (exclude some documents submitted by noyb, such as consumer studies or letters asking to extend the scope).

Inspiration can be drawn from the list of documents adopted in the Article 65(1)(a) guidelines and national policy documents on what constitutes ‘relevant information’. Alternatively, list of documents needed for a 64(1) request could function as inspiration (a request cannot be submitted via the IMI system if not all relevant documents are uploaded).

National Issues

National Issues