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.

Oral hearings

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


The use of oral hearings could often limit the need for hundreds of pages of submissions and ensure that procedures are focused on the core issues.

Ideal Solution

Law of SA hearing the parties/a party applies

CSAs must have the possibility to take part if they want
Data subjects must be heard in the language of their complaint

No “secret hearings”. If one party is heard, the other party must also be invited or at least be informed of the hearing taking place and be proactively provided with the minutes of the hearing 

Proposed Solution

Concept 2 leads to the local law applying.

National Issues

National Issues