From the list of issues, we have derived sixteen “core concepts”, which can provide solutions via high-level principles and rules.

Ideally, these concepts should be abstract enough to capture many problems, with a simple rule or principle that can be included in various provisions throughout the new Regulation.

When developing these principles, we have actively considered existing mechanisms in EU law, such as instruments in procedural rules, which seem to have many common features with GDPR procedures.

Concept 8: Defining cooperation
under Article 60

Currently Article 60 GDPR only defines that SAs shall “cooperate”, but lacks any specific rules on this cooperation.

While the GDPR and the EDPB guidelines seem to follow the idea of active cooperation and joint decision-making, most CSAs only function as a “post box”, while LSAs are left with running the procedures. A general section about the details of such cooperation would be useful to ensure that there is a common understanding of the practical meaning of “cooperation”.