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In its plenary meeting held in April 2017, Working Party 29 (WP29) examined certain critical matters regarding the implementation of Regulation 2016/679, the s.c. General Data Protection Regulation (GDPR). In that occasion, WP29 approved the Revised Guidelines on DPOs (Revised Guidelines), which contain also the following highlights compared to the Guidelines on Data Protection Officer (Guidelines) previously published. Accountability principle. The Revised Guidelines clarifies […]

  On December 13, 2016, EU Article 29 Data Protection Working Party “(WP29”) dealt with several critical matters with regards to the implementation of the General Data Protection Regulation (GDPR) and the Privacy Shield. It also dealt with the enforcement measures on cases having a cross-border effect. As for the GDPR’s implementation, the WP29 importantly adopted: […]

On 28 April 2020, the Belgian DPA sanction Proximus SA (previously Belgacom) for €50,000 on two basis:  non-cooperation under Article 31 of the GDPR and violation of Article 38(6) of the GDPR by appointing as DPO the director of one of its departments (Head of Compliance, Risk and Audit). The problem with the latter was conflict […]

Finalised GDPR Guidelines – Guidelines on Data Protection Officers (DPO), more here; – Guidelines on the right to data portability, more here; – Guidelines for identifying a controller or processor’s Lead Supervisory Authority, more here; – Guidelines on Data Protection Impact Assessment (DPIA) and determining whether processing is “likely to result in a high risk”, […]

In its plenary meeting held in April 2017, Working Party 29 (WP29) examined certain critical matters regarding the implementation of Regulation 2016/679, the s.c. General Data Protection Regulation (GDPR). After having examined the comments received during the public consultation which ended on February 15, 2017 (see here), WP29 adopted the final versions of several guidelines, and […]

In its plenary meeting held in April 2017, Working Party 29 (WP29) examined certain critical matters regarding the implementation of Regulation 2016/679, the s.c. General Data Protection Regulation (GDPR). In that occasion, WP29 approved the Revised Guidelines on DPOs (Revised Guidelines), which contain also the following highlights compared to the Guidelines on Data Protection Officer (Guidelines) previously published. Accountability principle. The […]

Francesca Giannoni-Crystal and Cristina Vicarelli In Section 3.5 of Article 29 Working Party (WP29)’s Guidelines on Data Protection Officer (“DPOs”) (“Opinion”), the WP29 discusses the issue of conflict of interest for DPO. See here for more information on this opinion. The WP29 points out that while Article 38(6) GDPR allows a DPO to perform “other tasks and duties”, […]

Article 37(5) General Data Protection Regulation (GDPR) does not list with particularity the professional skills that should be considered when designating the Data Protection Officer (“DPO”). It provides: The data protection officer shall be designated on the basis of professional qualities and, in particular, expert knowledge of data protection law and practices and the ability […]

Article 37(5) General Data Protection Regulation (GDPR) does not list with particularity the professional skills that should be considered when designating the Data Protection Officer (“DPO”). It provides: The data protection officer shall be designated on the basis of professional qualities and, in particular, expert knowledge of data protection law and practices and the ability […]

In Section 3.5 of Article 29 Working Party (WP29)’s Guidelines on Data Protection Officer (“DPOs”) (“Opinion”), the WP29 discusses the issue of conflict of interest for DPO. See here for more information on this opinion. The WP29 points out that while Article 38(6) GDPR allows a DPO to perform “other tasks and duties”, the organization must avoid appointment in which those […]