As deliberations on the General Data Protection Regulation (“GDPR”) between the trialogue parties European Parliament, European Council, and European Commission reach the final stages, the Conference of the Data Protection Commissioners of the German Federation and the German States (the “Conference”) has publicly criticized crucial points of the GDPR.
The Conference is calling on the trialogue parties to address its concerns regarding data economy, purpose limitation, individual’s consent, data subject’s rights and profiling, the need for data protection officers in private and public bodies, and the transfer of data to authorities and courts in third countries. The Conference has highlighted its positions on the matters outlined below:
- Data Reduction and Data Economy as Design Objectives
- No Softening of Purpose Limitation
- Consent Must Be Explicit
- Data Subject’s Rights and Profiling
- Data Protection Officers in Private and Public Bodies
- Data Transfers to Authorities and Courts in Third Countries