Added value of EDPB guidance documents (e.g. procedural guidelines) is unclear
Article(s) involved (national, EU, or other): Article 70(1) GDPR.
Problem
Many statements within procedural guidelines are formulated in weak terminology often vaguely prescribing the required action of SAs. This is a result of the lack of unanimity among EDPB members: the text is always a compromise.
Ideal Solution
Many statements from the EDPB’s procedural and internal guidance documents will have to be clarified before allowing their adoption within a procedural regulation. SAs can increase the authoritative character of guidelines by referring to it in their final binding decisions and publishing guidance on its website (creating legitimate expectations).
Proposed Solution
This is addressed by the Regulation overall.