NAID-Europe is preparing to respond to the European Commission’s (EC) recent request for public consultation

NAID-Europe is preparing to respond to the European Commission’s (EC) recent request for public consultation on its ideas to ensure effective and comprehensive protection of personal data. Among the Commission’s promising ideas (as put forth in the seed document) that NAID-Europe will directly comment on are:

-   Assessing the need to strengthen existing provisions on sanctions, for example, by explicitly including criminal sanctions in cases of serious data protection violations.

-   Making the appointment of an independent Data Protection Officer mandatory and harmonising the rules related to their tasks and competencies, while reflecting on the appropriate threshold to avoid undue administrative burdens, particularly on small and micro-enterprises.

-   Including in the legal framework an obligation for data controllers to carry out a data protection impact assessment in specific cases—for instance, when sensitive data is processed, or when the type of processing otherwise involves specific risks, in particular when using specific technologies, mechanisms or procedures.

-  How to strengthen, clarify and harmonise the status and the powers of the national Data Protection Authorities in the new legal framework, including the full implementation of the concept of “complete independence”.