EDPB binding directions too broad or disregarded Article(s) involved (national, EU, or other): Article 65. Problem When implementing the EDPB decision, SAs ‘must’ follow the binding directions of the EDPB. These binding directions, however, are often...
EDPB deadline for decision-making is too short Article(s) involved (national, EU, or other): Article 65 and 66. Problem 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...
Added value of EDPB guidance documents (e.g. procedural guidelines) is unclear Article(s) involved (national, EU, or other): Article 70(1) GDPR. Problem Many statements within procedural guidelines are formulated in weak terminology often vaguely prescribing the...
Procedural rights – informing the parties about the consistency mechanism Article(s) involved (national, EU, or other): Problem Today, there is no obligation to formally notify the parties that a decision under the consistency mechanism has been submitted to the...
Procedural rights – right to be heard at the EDPB level Article(s) involved (national, EU, or other): Problem Rules of Procedure (article 11.2) mentions the right to be heard by the affected parties but the text should be further clarified as to: what is...
