Relevant information to share in the cooperation procedure Article(s) involved (national, EU, or other): Article 60 GDPR Problem Article 60 does not define what should be shared with the other SAs (draft decision, complaints, submissions of the parties, attachments,...
LSAs respond differently to RROs Article(s) involved (national, EU, or other): Article 60 GDPR Problem Some LSAs submit a revised draft decision for a new round of consultation (as the GDPR requires), while other LSAs submit certain documents (such as composite...
Threshold for submitting a relevant and reasoned objection (RROs) is very high Article(s) involved (national, EU, or other): Article 60 GDPR Problem As a CSA it might be very difficult to substantially reason an objection (especially when a CSA is not well informed...
Effective procedure – differences in confidentiality requirements among SAs Article(s) involved (national, EU, or other): Problem In theory, confidentiality requirements could hinder SAs to exchange relevant information in the IMI system with other SAs or the...
Effective procedure – emergency procedure Article(s) involved (national, EU, or other): Article 61(8), 62(7) and 66 GDPR. Problem The emergency procedure under Article 66 GDPR is rarely used and the possibilities to trigger Article 66 GDPR in cases where urgency...
