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...
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...
