The Federation of European Data and Marketing (FEDMA) strongly supports the general objective of the Regulation laying down additional procedural rules relating to the enforcement of GDPR to streamline cooperation between data protection authorities (DPAs) when enforcing the General Data Protection Regulation (GDPR) in cross-border cases. We welcome the proposal’s emphasis (i) on the reliance of amicable settlements, (ii) on the different procedural situation between complainants and parties under investigation, and (iii) the possibilities for the defendants to submit their views prior to the adoption of the final decision.
There remain nevertheless some areas of improvements, specifically about the information provided to the parties under investigation and their right to be heard. Additionally, it is fundamental that this proposal remains an instrument to deal with all cross-border cases involving any kind of organization. EU policymakers should avoid turning the proposed Regulation into a tool to exclusively address cross-border cases involving large online platforms and only one regulator as the lead authority. Finally, we regard this proposal as a steppingstone to engage in a more comprehensive dialogue on how to enhance GDPR implementation on other key elements of the EU data protection framework in view of the upcoming review of the GDPR by the European Commission.
Find here the full position paper
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