Admissibility – Formal requirement: e-gov solution
Article(s) involved (national, EU, or other): Article 77 GDPR
Problem
Some SAs refuse complaints that are not filed via a national e-Gov access system or solution, whereas the complainant might not have the possibility to do so (e.g. because she or he is not a resident or because an organisation is filing under Article 80 GDPR).
Ideal Solution
The new text should oblige SAs to accept complaints without requiring the use of any e-gov access system. Or, as a minimum, the e-gov solutions from other Member States should be accepted throughout the EU (see also eIDAS).
Proposed Solution
Concept 2 would allow to ensure that the national law of the filing SA is relevant for any rules on the admissability of the law and other SAs may not review the admissability.
