Concept 4: Separate procedural decisions from final decision and early European resolutions on procedural disagreements Under the current practice, SAs are meant to “cooperate” throughout the procedure. However, in practice, CSAs are only left to raise reasoned...
Concept 3: Improved and upfront clarification of jurisdictionand SA roles The provisions of Article 4(22), 4(23), 55 and 56 GDPR have many factual and legal elements that need to be checked before the jurisdiction of a SA is clear. If this is done in detail, it can...
Concept 2: National procedures apply between each national SA and any national party, but the Regulation requires minimum standards and an equivalence principle Default Rule: National procedural law To further limit the interference of the Regulation with national law...
Concept 1: Scope is limited to international cooperation of SAs Article 2 of the Draft Regulation The Regulation shall be limited to cross-country procedures. This ensures that national cases, which remain the majority of all cases, are not interfered with. Member...
