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.

EDPB deadline for decision-making is too short

Article(s) involved (national, EU, or other): Article 65 and 66. 


A deadline of one month (potentially extended by a further month) is too little to take well-informed decisions. There is then no time to request additional information (in exceptional circumstances), translate those documents, organize hearings, request the EDPB approval for the inclusion of additional documents in the file, etc. 

Ideal Solution

Deadlines of the EDPB should be extended when ecessary in exceptional cases. Examples can be found in other basic regulations from EU agencies with decision-making competences.

Proposed Solution

Concepts 7, 8 and 11 should limit this problem.

National Issues

National Issues