Position paper - Input for European Commission initiative further specifying procedural rules related to the enforcement of the General Data Protection Regulation (GDPR)

The European Commission’s initiative aims to identify and harmonise procedural aspects of cooperation between national data protection supervisory authorities in cross-border cases. To this end, this consultation response presents recommendations that would support the robust enforcement of the GDPR across the European Union, including: specify procedural deadlines for cooperation between data processing agreement (DPAs) on cross-border cases; provide tools to DPAs to promote cooperation early in the investigation process; clarify the position of complainants in the procedural steps; streamline the way parties under investigation are heard during the procedure; and clarify how information is to be shared between the investigating DPA and the concerned supervisory authorities (CSAs).