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.

Redacted final decisions

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


The SAs have different approaches regarding the publication of their decisions.

  • Some SAs redact the names of the controllers whereas some decide on a case-by case basis;

  • Some identify controllers only as additional sanction (e. g. the CNIL / the Lux SA).

The systematic redaction of the name of the parties does not make much sense: transparency of the action of the SAs and controllers should be the rule, whereas confidentiality should only apply in certain specific cases.

Ideal Solution

The text should provide for harmonised rules regarding anonymisation, for example:

  • As a general rule, the names of legal persons should only be redacted where appropriate and in limited circumstances;

  • As a general rule, the names complainants should always be redacted or pseudonymised, otherwise this would disincentivise complaints.

Proposed Solution

Concept 15 relates to this issue.

National Issues

National Issues