Concept 10: Defining ex officio procedures In some cases, SAs have tried to “push” additional elements into ex officio procedures by LSAs, as there seems to be no mechanism to trigger new ex officio procedures by CSAs. The urge to expand existing procedures could be...
Concept 9: Defining the steps of complaints procedures Especially in complaints procedures, where the filing CSA and the LSA may have to deal with at least two parties, it seems that the initial procedure (e.g. defining the LSA, sending the case, the LSA accepting the...
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...
Concept 7: Joint case file, use of language, translations and length of documents Currently, the case files are “siloed” before each SA. There is no “joint file” in procedures under Article 60 to 66 GDPR. This causes major delays until CSAs and EDPB staff can,...
Concept 6: Recognition of different sizes of procedures (normal / minor / major) There is a chance that a European procedure could be too detailed for some minor procedures (e.g. a simple unanswered subject access request). At the same time, short deadlines or...
Concept 5: Quicker European decision processes for smaller decisions (e.g. procedural disagreements) via an EDPB sub-body An option to make more European decision making realistically possible, would be the introduction of a standing sub-committee or other sub-body...