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Stakeholder consultation periods on data protection guidelines too short

Today 10 EU trade associations (including Insurance Europe) expressed their concerns about the short stakeholder consultations during the development of guidelines under the EU General Data Protection Regulation (GDPR). The associations also expressed concerns that the guidelines effectively introduce additional rules, which are not in line with the agreement by co-legislators in the Level 1 text.

The Article 29 Working Party, which will soon become the European Data Protection Board (EDPB), is responsible for the development of guidelines under the GDPR. The associations welcomed the possibility to provide feedback on the guidelines, but argued that the consultation processes of the Working Party, which have taken place so far with 30-day deadlines to respond, are much too short. To ensure the transparency and success of the guidelines, the associations suggest a consultation period of 8 weeks. In the longer term, the EDPB should follow the European Commission guidelines for stakeholder consultation under the Better Regulation agenda, which provide for a 12-week public consultation period. 

In the letter, concerns were also expressed that the guidelines are not in line with the agreement by European co-legislators in the Level 1 text. The guidelines are non-binding, but can still be introduced as compulsory requirements at national level. It is therefore important that the guidelines provide clarity and help facilitate implementation, and do not undermine the existing Level 1 provisions that were set as part of this political agreement.

As the financial services industry needs to receive guidance in a timely manner to prepare for the entry into force of the GDPR on 25 May 2018, the associations called on the Working Party to develop the final GDPR guidelines as swiftly as possible. 

Published 13 July 2017
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