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Report on the application of the General Data Protection Regulation

Justice and fundamental rights

The Commission will report on the application of the General Data Protection Regulation, six years after its entry into application.

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Public consultation

ID: 14054

Lobbying Activity

89 responses

German Industry BDI Urges Stability and Better GDPR Guidance

Bundesverband der Deutschen Industrie e.V., 8 Feb 2024

BDI opposes major legislative changes, favoring better guidance and practical support for implementation. They recommend reducing compliance complexity for small businesses and involving stakeholders earlier in policy development.
Businesses would avoid significant disruption and high costs associated with new legislative requirements.
Society loses potential climate and energy benefits due to current data processing restrictions.

DIGITALEUROPE warns against premature reopening of GDPR rules

DIGITALEUROPE, 8 Feb 2024

The group argues that reopening the GDPR is premature before new regulations are implemented. They request practical guidance to reduce compliance burdens.
Aligning regulations would reduce legal uncertainty and prevent conflicting enforcement for digital businesses.
Individuals might face restrictions on their data rights to prevent potential misuse against companies.

Apple urges EU to preserve strong GDPR framework

Apple Inc., 8 Feb 2024

Apple opposes broad reopening or revision of the GDPR. The company supports existing principles and wants to prevent any undermining of the One Stop Shop mechanism. Apple argues against attempts to reverse European Court rulings that some companies seek to justify lower data protection standards.
This preserves Apple's competitive advantage from its privacy-focused business model over competitors.
Competitors relying on data monetisation lose opportunities to weaken privacy protections through GDPR changes.

Telefónica urges consistent GDPR enforcement to boost digital innovation

Telefonica, S.A., 7 Feb 2024

They request authorities prioritize corrective measures over sanctions and maintain a principle-based approach. They also seek better cross-border harmonization and the avoidance of sector-specific regulations.
Harmonized enforcement and clearer rules would reduce compliance costs and support technological investment.
Individuals may find their data access rights restricted to only those deemed effectively useful.

Consultation response

Vereniging VNO-NCW, 7 Feb 2024

Call for evidence regarding review GDPR 2024 Input from VNO-NCW/MKB Nederland The Dutch Confederation of Dutch Industries and employers (VNO-NCW/MKB-Nederland) welcomes the opportunity to provide input for the evaluation of the General Data Protection Regulation (GDPR) 2024. We underwrite the input…

Swedish Enterprise urges GDPR competitiveness check and reform

Confederation of Swedish Enterprise, 8 Feb 2024

The group seeks measures to counter unnecessary bureaucracy and unjustified restrictions on business activities. They recommend updating definitions of personal data and anonymisation to support AI-driven innovation. Additionally, they propose limiting data access rights to prevent strategic misuse in legal disputes.
Clarified rules would reduce resource-intensive compliance work and lower high administrative costs.
Individuals would lose their ability to use data requests for gathering evidence in disputes.

Insurance Europe urges practical GDPR interpretation to support digital innovation

Insurance Europe, 7 Feb 2024

Insurance Europe requests that the Commission address obstacles to innovation and simplify international data transfers. They call for a more risk-based approach from regulators and clarification on the legal basis for processing health data.
These changes would reduce administrative burdens and provide legal certainty for adopting new technologies.
Individual data subjects may lose the right to access personal data stored in backup systems.

Consultation response

Deutsche Industrie- und Handelskammer, 8 Feb 2024

Unter dem Dach der Deutschen Industrie- und Handelskammer (DIHK) sind die 79 Industrie- und Handelskammern (IHKs) zusammengeschlossen. Unser gemeinsames Ziel: Beste Bedingungen für erfolgreiches Wirtschaften. Auf Bundes- und Europaebene setzt sich die DIHK für die Interessen der gesamten…

Austrian Economic Chamber Urges GDPR Exemptions For Small Businesses

Wirtschaftskammer Österreich, 2 Feb 2024

The organization requests exemptions for small businesses and pragmatic data distinctions. They want clarified rules regarding how data protection interacts with fraud laws.
Simplified rules would reduce the administrative burden and legal risks for firms.
Individuals may find it harder to exercise their rights or access information.

European Banking Federation seeks flexibility in GDPR enforcement

European Banking Federation, 8 Feb 2024

The federation requests uniform GDPR interpretation across member states, better coordination between data protection and sectoral financial regulations, and preservation of the regulation's risk-based approach. They argue current guidelines are too prescriptive and undermine banks' ability to implement compliance autonomously.
This would reduce operational complexity and give banks more autonomy in compliance decisions.
Consumers may face weaker data access rights if request timelines are extended.

French business group MEDEF opposes reopening GDPR rules

Mouvement des Entreprises de France, 2 Feb 2024

MEDEF opposes reopening the regulation to avoid additional compliance costs. They want authorities to prioritize a risk-based approach over rigid interpretations. The group calls for better alignment between data rules and new technologies.
Maintaining the current text protects firms from expensive new technical and legal requirements.
National regulators lose power to impose stricter local interpretations that deviate from business interests.

French Large Companies Urge Risk-Based GDPR Approach

Association Française des Entreprises Privées / French Association of Large Companies, 8 Feb 2024

AFEP demands that data authorities return to a risk-based approach and avoid rigid interpretations. They seek better dialogue and clearer rules for identifying individuals during access requests. The group calls for proportionate interpretations that support business innovation.
This would lower compliance costs and help firms innovate with artificial intelligence.
Specialized law firms and privacy activists would lose the ability to pursue lawsuits.

Ibec warns EU against premature reopening of GDPR rules

Ibec, 8 Feb 2024

Ibec argues reopening GDPR is premature due to uncertainty from new laws like the AI Act. They want prioritised coherence between regulations and better guidance using real-world scenarios. They also urge safeguarding international data transfers and the One-Stop-Shop.
This approach provides legal certainty and prevents increased administrative costs for businesses.
Weakening current mechanisms would make it harder for individuals to exercise privacy rights.

Finnish Energy demands clearer rules to end GDPR legal uncertainty

Finnish Energy - Energiateollisuus ry, 1 Feb 2024

Finnish Energy requests more concrete, real-life guidance from authorities to resolve significant legal uncertainty. They call for clearer definitions of roles and simplified rules for international data transfers.
Specific guidance would reduce the heavy administrative and financial burden of complex compliance assessments.
Dominant tech platform providers could lose their disproportionate influence over data processing agreements and terms.

German insurers urge flexible GDPR rules to enable digital innovation

Gesamtverband der Deutschen Versicherungswirtschaft e.V., 8 Feb 2024

The group requests replacing the prohibition on automated decisions with transparency rules and calls for a clear legal basis for processing health data. They also seek a risk-based approach for international transfers and clearer definitions for anonymized data.
Removing these rules would lower administrative costs and accelerate the rollout of automated services.
Consumers and staff would lose the ability to use data requests for legal leverage.

Bitkom calls for GDPR reforms to boost digital innovation

Bitkom e.V., 8 Feb 2024

Bitkom requests more flexible rules for emerging technologies and the removal of overlapping regulations. They urge authorities to adopt a risk-based approach instead of a zero-risk policy. The group also asks for clearer guidelines on data anonymization and international transfers.
Streamlining regulations would reduce the high compliance costs and bureaucratic burden on digital businesses.
National regulators would see their discretionary power limited by stricter European Commission definitions.

VDMA urges EU to cut GDPR red tape for SMEs

Verband Deutscher Maschinen- und Anlagenbau e.V., 7 Feb 2024

The organization calls for a pragmatic application of rules to reduce burdens on smaller industrial companies. They advocate for abolishing excessive documentation requirements and providing better support through better-resourced regional authorities.
Lowering administrative overhead would reduce compliance costs and prevent innovation-inhibiting effects in mechanical engineering.
Transparency advocates may find it harder to monitor compliance if documentation requirements are eased.

ITI urges pragmatic GDPR application to foster tech innovation

ITI - The Information Technology Industry Council, 8 Feb 2024

The ITI requests a more proportionate application of rules without changing the underlying legislation. They advocate for streamlined international data transfers and clearer guidance on data processing. They also suggest requiring consumers to exhaust internal company complaints before contacting regulators.
This would reduce compliance costs and administrative burdens while facilitating global business operations.
Consumers may find it harder to access regulators directly due to mandatory internal appeals.

DOT Europe Urges End to Absolutist GDPR Enforcement

DOT Europe, 8 Feb 2024

The group demands that regulators abandon "absolutist" interpretations. They want a "risk-based approach" that balances privacy with innovation. They urge authorities to prioritize constructive dialogue over financial penalties.
This shift would reduce legal uncertainty and help companies launch new products.
Consumer groups lose the prioritization of privacy rights over corporate business interests.

German employers demand curbs on abusive employee data requests

Bundesvereinigung der Deutschen Arbeitgeberverbände e.V., 8 Feb 2024

The BDA requests longer deadlines for data access and the right to reject requests used for non-data protection purposes. They also advocate for exempting small businesses from maintaining processing records.
This would reduce administrative burdens and limit the legal leverage employees hold during disputes.
Employees would lose a tool used to strengthen their position during dismissals or severance negotiations.

E.ON seeks GDPR reforms to facilitate energy grid innovation

E.ON SE, 8 Feb 2024

E.ON proposes allowing pseudonymised data processing for product development and issuing binding recommendations. They advocate for extending breach notification deadlines to five working days. They also request adopting risk-based assessments for data transfers.
This would reduce operational costs and eliminate legal barriers to smart grid development.
Consumers may suffer from delayed transparency regarding data security incidents and reduced privacy oversight.

Austrian Industry Demands GDPR Reform to Cut Administrative Burdens

Vereinigung der österreichischen Industrie - Industriellenvereinigung, 6 Feb 2024

The federation requests a reduction in red tape and a narrower definition of personal data. They also advocate for a group privilege and harmonized international data transfer rules.
Companies would significantly reduce internal resource expenditure and improve their overall market competitiveness.
Privacy advocates and individuals would face restricted access to corporate data and reduced litigation power.

BSA Urges Improved GDPR Harmonization to Foster European Innovation

Business Software Alliance, 8 Feb 2024

BSA recommends improving the consistency mechanism to reduce legal fragmentation across EU Member States. They suggest strengthening international data transfer tools and ensuring privacy rules align with new AI regulations. The group also seeks clearer standards for business-to-business contractual relationships and data subject requests.
Uniform enforcement would reduce the burden of complying with varying national requirements.
Individual citizens might face higher hurdles when exercising their personal data rights.

European Tech Alliance demands harmonised and risk-based GDPR enforcement

European Tech Alliance, 7 Feb 2024

The alliance calls for a consistent and harmonised approach to address diverging interpretations by national authorities. They advocate for a risk-based approach that balances data privacy with other fundamental rights. Furthermore, they request greater engagement with industry and the promotion of sector-specific codes of conduct.
Greater harmonisation would reduce legal uncertainty and the high costs of adapting to local requirements.
Legal practitioners and litigants using data rights for financial gain would face restricted opportunities.

Nordic media group Schibsted urges more practical GDPR enforcement

Schibsted, 7 Feb 2024

Schibsted believes reopening the GDPR is not necessary, but calls for improvements in its enforcement. They request that authorities focus on facilitating practical compliance and return to a risk-based approach. Additionally, they argue the outdated ePrivacy rules should be repealed to ensure legal consistency.
This would reduce administrative burdens and simplify compliance across their multiple digital brands.
Privacy advocates may see the repeal of ePrivacy rules as weakening digital consent protections.

Insurance Ireland urges sector-specific GDPR guidance and transfer certainty

Insurance Ireland, 29 Jan 2024

The organization seeks sector-specific guidelines for insurers and a stable framework for international data transfers. They also recommend tailoring data access responses to what the individual specifically requests.
Clearer guidelines and streamlined requests would provide greater legal certainty and lower administrative costs.
Individuals might receive less comprehensive information if access requests are limited to specific items.

European Publishers Council urges EU to stop Big Tech weaponising GDPR

European Publishers Council, 8 Feb 2024

The EPC demands the Commission stop large platforms from using privacy rules to dominate the advertising market. They want the draft ePrivacy Regulation scrapped and replaced with a more integrated approach. They advocate for more flexibility in using legitimate interest rather than relying exclusively on user consent.
These changes would help publishers regain advertising revenue and reduce their complex administrative compliance burdens.
Dominant tech platforms would lose the ability to dictate industry-wide privacy standards to their own advantage.

European doctors urge harmonized rules for health data research

Standing Committee of European Doctors, 8 Feb 2024

Doctors request long-promised guidelines for processing research data to ensure proper harmonization. They also call for better staffing of data authorities and clearer data laws.
Clearer rules would facilitate multi-country medical studies and support the digitization of healthcare.
Patient empowerment and healthcare modernization are hindered by inconsistent legal interpretations across Member States.

La Poste Urges More Pragmatic GDPR Enforcement

LA POSTE, 7 Feb 2024

La Poste requests that authorities consider economic realities and provide pragmatic guidelines. They also want regulators to take charge of complex third-country legal assessments.
The company would benefit from lower compliance costs and fewer barriers to innovation.
Privacy advocates lose when regulators prioritize commercial interests over strict data protection rules.

ZVEI Urges Comprehensive GDPR Reform to Boost Innovation

ZVEI e.V. - Verband der Elektro- und Digitalindustrie, 8 Feb 2024

ZVEI calls for a fundamental legislative reform to move toward an enabling data protection framework. They request rethinking the prohibition principle and simplifying rules for international data transfers.
Proposed changes would significantly reduce bureaucratic burdens and operational costs for businesses.
Citizens could face higher privacy risks from looser standards regarding data re-identification.

App Association seeks simpler GDPR rules for small developers

ACT | The App Association, 8 Feb 2024

The association requests simpler information obligations for smaller firms and stronger, uniform enforcement. They argue privacy rules must remain flexible enough for emerging artificial intelligence technologies.
Strict enforcement would prevent compliant small businesses from being disadvantaged by non-compliant competitors.
Non-compliant companies would lose the financial advantage gained by avoiding data protection costs.

5Rights Foundation Urges Specific EU Safeguards for Children's Data

5Rights Foundation, 8 Feb 2024

The 5Rights Foundation requests that the EU adopt clear guidelines to ensure digital services prioritize children's best interests by design and default. They call for mandatory data protection impact assessments and risk-based age assurance measures for services children are likely to access.
This would establish their proposed frameworks as the legal standard for digital products.
Digital services face higher compliance burdens and restrictions on nudging or profiling children.

European public banks urge reduced GDPR administrative and legal burdens

European Association of Public Banks and Funding agencies AISBL, 8 Feb 2024

The association requests reduced documentation duties and a clearer distinction for business-related data. They also propose shifting design responsibilities to manufacturers and limiting data access rights in legal disputes.
Public banks would face fewer documentation costs and technical hurdles when deleting data.
Employees and customers lose extensive rights to access and delete their personal information.

CCIA Europe Urges Improved GDPR Harmonisation and Data Flows

Computer and Communications Industry Association, 7 Feb 2024

The association requests more adequacy decisions and more flexibility for international data transfers. They seek a balanced and pragmatic approach that recognizes the value of alternative legal bases. Finally, they call for a strengthened One-Stop-Shop mechanism to guarantee harmonised implementation.
This would provide greater legal certainty and reduce operational costs for cross-border tech firms.
National regulators lose the ability to mandate data localization or set independent enforcement agendas.

Finnish IT Center Urges GDPR Reform to Support Scientific Research

CSC – IT CENTER FOR SCIENCE LTD., 8 Feb 2024

CSC requests consistent EU-wide interpretation to reduce research bureaucracy and data fragmentation. They propose clarifying pseudonymization rules and re-evaluating data minimization for data-intensive research.
This would reduce administrative burdens and costs for developing research and innovation services.
Privacy advocates lose protections if data minimization principles are relaxed for research purposes.

FESI urges clearer GDPR guidance and better regulatory alignment

Federation of the European Sporting Goods Industry, 8 Feb 2024

The industry requests practical guidance from national authorities to resolve confusion around data subject rights. They seek legal certainty on international transfers and better consistency between GDPR and new laws.
This would allow companies to reallocate resources from complex legal paperwork to general privacy.
Counterfeiters and rogue sellers currently exploit data privacy rules to hide their identities.

Unipol Group urges EU to simplify health data processing rules

Unipol Assicurazioni S.p.A:, 8 Feb 2024

Unipol requests a new legal basis to process sensitive health data for insurance contracts. They also want to maintain flexible rules for data use based on legitimate interests. Finally, they seek sector-specific laws regarding access to vehicle data.
These changes would reduce operational conflicts and provide the insurance industry with legal certainty.
National authorities lose the power to implement stricter data protections at the local level.

Allied For Startups Urges Regulatory Stability Over New Rules

Allied For Startups asbl, 7 Feb 2024

Allied For Startups calls for regulatory stability and consolidation instead of reopening existing laws. They request further harmonisation and clearer guidance to reduce the complexity of legal compliance.
Maintaining the current framework prevents new cost barriers that disproportionately impact smaller tech firms.
Consumers lose because high entry barriers reduce competition and lead to higher market concentration.

Czech Industry Group Seeks Harmonized GDPR and Practical Data Rules

Svaz průmyslu a dopravy ČR, 6 Feb 2024

The organization requests better coordination between authorities to ensure a harmonized privacy regime and a simplified international data transfer process. They also propose allowing companies to refuse data access requests that are being weaponized for litigation.
Increased legal certainty and simplified procedures would reduce administrative burdens and the risk of massive turnover penalties.
Consumers and employees may find it more difficult or expensive to exercise their right to access personal data.

EuroISPA urges pragmatic GDPR guidance and reduced SME complexity

European Internet Services Providers Association, 8 Feb 2024

Simplify user information and ensure data protection authorities provide more pragmatic guidance. The association advocates for a risk-based approach to support innovation and new technologies.
Clearer rules would reduce compliance costs and encourage investment in digital technology.
Privacy groups could face higher risks if authorities move away from strict standards.

SIOPE Urges GDPR Harmonisation to Protect Paediatric Cancer Research

European Society for Paediatric Oncology, 8 Feb 2024

The organization recommends harmonised interpretation of GDPR rules to remove barriers to cross-border research. They request one-time broad consent for data reuse and treating pseudonymised data as anonymised. They also advocate for removing explicit consent requirements for population-based cancer registries.
Streamlined rules would facilitate international data exchange necessary for scientific breakthroughs in rare diseases.
Patients seeking individual control over every research use of their data may lose oversight.

VAUNET urges balanced GDPR enforcement for media advertising

VAUNET - Verband Privater Medien e. V., 8 Feb 2024

VAUNET requests a balanced interpretation that does not treat user consent as the default. They also want to prevent people using data access rights to gain lawsuit advantages.
This would protect advertising revenues that fund private media and ensure plurality of opinions.
Litigation-focused individuals lose a tool for gathering evidence against companies in civil proceedings.

Cloudflare warns GDPR data localization rules harm cybersecurity

Cloudflare, 8 Feb 2024

Cloudflare wants the EU to clarify that IP addresses are not always personal data. They also propose exempting cybersecurity data from international transfer restrictions to ensure safety.
This would allow the company to operate its global network without building expensive Europe-only infrastructure.
EU citizens and businesses would suffer from weaker security and exclusion from global online marketplaces.

PostEurop calls for sector-specific international data transfer tools

Association of European Public Postal Operators, 8 Feb 2024

The organization requests that international data transfer tools accommodate a sector-specific approach. They urge national authorities to consider the unique nature of public service activities when interpreting rules.
Specific sectoral rules would reduce interpretation risks and compliance challenges for members.

WFA Urges EU Clarity on GDPR and Digital Laws

World Federation of Advertisers, 7 Feb 2024

The WFA seeks harmonized guidelines to prevent regulatory fragmentation across Member States. They support the risk-based approach and urge clarity on the interplay with new digital laws.
Standardized EU rules would allow global brands to streamline operations and minimize legal risks.

ESMO calls for harmonised data rules to boost cancer research

European Society for Medical Oncology (ESMO), 6 Feb 2024

ESMO calls for uniform rules to facilitate oncology research and international collaboration. They propose 'one-time consent' for future studies and 'no-consent' for disease registries.
Standardised procedures would reduce administrative burdens and financial costs for multi-national projects.
Current data restrictions harm minority groups by delaying identification of specific health problems.

United Internet Urges GDPR Flexibility to Boost AI Innovation

United Internet AG, 7 Feb 2024

The company requests flexible rules for AI development and pseudonymous data. They suggest adding proportionality requirements to data subject access requests.
This would lower regulatory costs and accelerate the deployment of AI products.
Privacy advocates and citizens would lose the absolute right to access personal data.

German banking industry urges less bureaucratic and risk-based GDPR

Die Deutsche Kreditwirtschaft, 7 Feb 2024

The committee proposes reducing detailed information requirements and bureaucratic documentation obligations. They also want to restrict data access rights to prevent misuse in non-privacy legal disputes.
This would reduce operational compliance costs and limit liability risks for financial institutions.
Consumers could receive less transparent information and lose a tool for legal disputes.

ACCIS urges uniform GDPR enforcement to support credit markets

ACCIS, 8 Feb 2024

ACCIS requests more uniform enforcement by national authorities to ensure a level playing field. They seek clear guidance on using legitimate interest for processing financial data. They also oppose classifying credit scoring as high-risk artificial intelligence.
Clearer rules would reduce administrative costs and allow for more efficient automated assessments.
Consumers lose transparency as the industry seeks to protect trade secrets related to scoring logic.

Consultation response

European Association of E-Pharmacies, 8 Feb 2024

The European Association of E-Pharmacies (EAEP), which represents online pharmacies and their patients on the European continent, welcomes the opportunity to provide its feedback on the implementation of the General Data Protection Regulation (GDPR), six years after its implementation. The EAEP…

Consultation response

European Blood Alliance, 7 Feb 2024

The European Blood Alliance (EBA) represents public and non-profit blood establishments. Blood establishments are responsible for the collection, testing, and preparation of blood products for hospitals and pharmaceutical companies, and as such provide a public service that is essential for the…

Consultation response

Stiftung Ordnungspolitik - Centrum für Europäische Politik, 8 Feb 2024

Dear Sir or Madam, Cep thanks you for the opportunity to provide feedback on the application of the GDPR. Free of vested interests and party-politically neutral, the Centres for European Policy Network (https://www.cep.eu/) provides analysis and evaluation of European Union policy, aimed at…

German tax advisers demand simplified GDPR rules for SMEs

Bundessteuerberaterkammer, 8 Feb 2024

The organization requests reducing information requirements to avoid overwhelming small businesses. They advocate for including software manufacturers in the regulation's scope. Additionally, they seek standardized rules for data anonymization and uniform interpretations.
Proportionate rules would significantly lower compliance costs and legal uncertainty for members.
Software developers and manufacturers would face increased liability and new regulatory costs.

Consultation response

Science Europe, 7 Feb 2024

Public research-funding and research-performing organisations often collaborate and finance research projects with partners from different countries within and outside the European Union. These collaborations are usually established with multiple partners from the public sector, which involve the…

Consultation response

Confederation of European Security Services, 8 Feb 2024

Please find the input from the Confederation of European Security Services (CoESS) in the attached paper.

Consultation response

DATEV eG, 30 Jan 2024

DATEV welcomes the opportunity to provide feedback on the application of the GDPR. DATEV sees a need for improvement in the following four areas in particular. Clarifying Definitions and Terminology Further clarification is needed regarding the definition of personal data under Art. 4 GDPR. It…

German auditors urge GDPR updates for cloud and AI

Institut der Wirtschaftsprüfer in Deutschland e.V., 7 Feb 2024

The IDW suggests clarifying that certifications should legally limit the scope of audit rights. They demand measures to prevent the misuse of data access rights for litigation. They also call for an adapted legal basis for artificial intelligence.
Auditors would face lower compliance costs and reduced exposure to compensation claims for formal violations.
Citizens would find it more difficult to obtain full copies of their data from organizations.

Consultation response

European Association for the Consumption-based billing of Energy Costs, 8 Feb 2024

EVVE welcomes the opportunity to provide its feedback concerning the report on the General Data Protection Regulation. Please find our contribution in the attached document.

Europe’s Largest Internet Association Demands Proportional GDPR Implementation

eco - Verband der Internetwirtschaft, 8 Feb 2024

The association calls for proportionate rules and clearer guidance for small businesses and research institutions. They advocate for realistic anonymization standards and a stable framework for international data transfers.
Lowering compliance barriers and administrative complexity would allow internet companies to innovate more effectively.
Consumer privacy protections could weaken if data anonymization standards are lowered for economic reasons.

Consultation response

Alliance Digitale, 5 Feb 2024

Alliance Digitale is the main trade association for digital marketing activities in France representing more than 200 companies throughout the value chain.

European mutual insurers demand changes to GDPR health data rules

AMICE - Association of Mutual Insurers and Insurance Cooperatives in Europe, 8 Feb 2024

The association requests a legal exception for processing health data in insurance contracts. They also advocate for flexible data rules to support new technologies and innovation.
This move would resolve legal uncertainties and lower operational costs for insurance providers.
Policyholders may lose the absolute right to refuse the sharing of sensitive health information.

German Federal Bar demands better protection for lawyer-client confidentiality

Bundesrechtsanwaltskammer, 8 Feb 2024

They request stronger legal safeguards for professional secrecy during supervisory activities. They propose creating independent, self-regulated data protection authorities for lawyers.
These reforms would reduce regulatory interference in confidential lawyer-client relationships.
National supervisory authorities would face significant restrictions on their investigative powers.

Consultation response

Cigref, 7 Feb 2024

The document enclosed is a summary of the main points underlined by business users of digital services regaring the zpplication of the GDPR. If GDPR led to a higher awareness for data protection, there are several challenges that businesses must deal with and that raised legal uncertainties :…

Consultation response

ESOMAR, 8 Feb 2024

This paper attached is submitted on behalf of: EFAMRO the European Federation of Associations of Market Research Organisations. Founded in 1992, EFAMRO represents the interests of market, opinion and social research in Europe. Its members are national trade associations for research businesses in…

Consultation response

HOMO DIGITALIS ΑΣΤΙΚΗ ΜΗ ΚΕΡΔΟΣΚΟΠΙΚΗ ΕΤΑΙΡΕΙΑ, 6 Feb 2024

Homo Digitalis genuinely believes that the first five years of GDPR enforcement can be characterised as successful. The GDPR has undeniably served as a cornerstone in establishing strong guidelines for member states, setting a comprehensive framework for elevated data protection standards. Over the…

Consultation response

CIO Platform Nederland, 8 Feb 2024

CIO Platform Nederland is the association of business users of digital technologies in the Netherlands. By and large we hear from our members the same comments that have been submitted by the French association of business users of digital technologies, Cigref. In addition to their input, we have…

Consultation response

Beltug vzw/asbl, 8 Feb 2024

Consultation European Commission - Report on the General Data Protection Regulation 1 Reporting obligations are burdensome 2 Application of the GDPR in non-EU States 3 Unbalanced responsibility of the data holder 4 Unclear provisions leading to interpretation 5 Application of the GDPR and the…

Consultation response

SCHUFA Holding AG, 8 Feb 2024

Sehr geehrte Damen und Herren, wir bedanken uns für die Möglichkeit zur Rückmeldung zum Bericht über die Datenschutz-Grundverordnung. Über fünf Jahre nach Ablauf der Umsetzungsfrist der DSGVO stellen wir fest, dass die Regelungen insgesamt zu unflexibel sind. Zwar funktioniert das Konstrukt der…

Consultation response

Republiková únia zamestnávateľov, 8 Feb 2024

Our position is fully stated in the attached file. General overview is following: Several businesses have concerns that certain national data protection authorities are overstepping their powers under the General Data Protection Regulation (GDPR). This risks undermining the balanced approach to…

Consultation response

Associazione Italiana per l’Information and Communication Technology, 8 Feb 2024

The GDPR has had a significant impact on the way organisations collect, use and store personal data. It has improved transparency and accountability, and increased awareness. We thank for the opportunity to have our say on the impact of this regulation. please find herewith our input on the…

Consultation response

Deutscher Juristinnenbund e.V., 8 Feb 2024

Der Deutsche Juristinnenbund e.V. (djb) nimmt anlässlich der anstehenden Evaluierung der DSGVO Stellung. Der djb ist ein unabhängiger frauenpolitischer Verband, in dem sich Juristinnen, Volks- und Betriebswirtinnen zusammengeschlossen haben. Der Verband setzt sich für eine Fortentwicklung des…

Consultation response

Deutsche Forschungsgemeinschaft, 7 Feb 2024

Die Deutsche Forschungsgemeinschaft (DFG) finanziert als nationale Forschungsförderorganisation gemeinsame Forschungsprojekte mit Partnern aus verschiedenen Ländern innerhalb und außerhalb der Europäischen Union. Dies schließt in der Regel die Verarbeitung personenbezogener Daten ein. Infolgedessen…

Consultation response

DDV Deutscher Dialogmarketing Verband e.V., 7 Feb 2024

The German Direct Marketing Association (Deutscher Dialogmarketing Verband e. V.) welcomes the opportunity to provide input for the 2024 Report on the application of the General Data Protection Regulation (GDPR). The German Direct Marketing Association fully supports the Position Paper the…

Consultation response

Intrum AB, 8 Feb 2024

Intrum would like to see a (thorough) review of the GDPR, in particular the Articles 6, 33 and 34. In the meantime, we believe that a harmonized enforcement of the existing rules is a priority. Please see our full statement for further detail.

Consultation response

FORSETI (Doctrine), 8 Feb 2024

Le RGPD est incontestablement une réussite : en quelques années, le texte sest imposé comme létalon-or mondial de la réglementation des données personnelles. Il a cependant été écrit à une époque où lintelligence artificielle nétait quà ses prémisses. Si lambition de lUnion européenne est de…

Consultation response

Asociación Española de Economia Digital, 8 Feb 2024

Adigital Contribution COMMISSION 2024 REPORT ON THE APPLICATION OF THE GDPR European Commission Open Feedback Period The General Data Protection Regulation (GDPR) is the main piece of EU legislation guaranteeing the fundamental right to data protection. The GDPR entered into application on 25 May…

Consultation response

Wirtschaftsprüferkammer (Chamber of Public Accountants), 7 Feb 2024

Sehr geehrte Damen und Herren, anbei dürfen wir Ihnen die Stellungnahme der Wirtschaftsprüferkammer zur Initiative der Europäischen Kommission Bericht über die Datenschutz-Grundverordnung übermitteln. Wir würden uns freuen, wenn unsere Anregungen im Rahmen der weiteren Beratungen berücksichtigt…

Consultation response

Selbstregulierung Informationswirtschaft e.V., 8 Feb 2024

Selbstregulierung Informationswirtschaft e.V. - non-for profit - appreciates the opportunity to provide feedback to the European Commission's Call for Evidence related to the Commission's "Report on the General Data Protection Regulation". Please, find our responses and comments attached.

Consultation response

SCOPE Europe (Self and Co-Regulation for an Optimized Policy Environment in Europe), 8 Feb 2024

SCOPE Europe highly appreciates the opportunity to contribute to this call for feedback and remains available and eager to continuously support the European Commission's efforts regarding GDPR implementation. Against this background, please find our response here enclosed.

Consultation response

Verband Insolvenzverwalter und Sachwalter Deutschlands, 8 Feb 2024

COMMENTS ON THE APPLICATION OF THE GDPR Harmonization of Data Protection Guidelines for Office Holders in Restructuring and Insolvency Proceedings

Consultation response

Federation of European Business Information Services, 8 Feb 2024

FEBIS members are business information providers whose core business model is to provide creditworthiness assessments, credit scores and business information reports on businesses for businesses. Contrary to credit rating, credit scores are done on all businesses population of a country, using data…

Consultation response

EOS Holding GmbH, 7 Feb 2024

Please note that an attachment has been included with the form, containing the contribution of the EOS Group to the public consultation on the evaluation of the General Data Protection Regulation (GDPR).

Consultation response

Asociación Nacional de Establecimientos Financieros de Crédito (ASNEF), 7 Feb 2024

ASNEF, as the trade association of regulated financial institutions of Spain, hereby encloses feedback on the application of the General Data Protection Regulation (GDPR).

Consultation response

Hangzhou Hikvision Digital Technology Co., Ltd., 6 Feb 2024

Hangzhou Hikvision Digital Technology Co., Ltd. (Hikvision) is a world leading security product and solution supplier with offices in many EU Member States. We appreciate the opportunity to provide feedback and we were pleased to see that our previous input to the report on the application of the…

Consultation response

Association of Clinical Research Organizations, 8 Feb 2024

I write on behalf of the Association of Clinical Research Organizations (ACRO) which represents the worlds leading clinical research and technology organizations. ACRO member companies provide a wide range of specialized services across the entire spectrum of development for new drugs, biologics…

Consultation response

Internet Service Providers Austria, 8 Feb 2024

ISPA - Internet Service Providers Austria welcomes the Commissions initiative to continue reporting on how the rules of the GDPR have been applied, 6 years after their entry into application and the opportunity to provide comments to the Report on the GDPR. ISPA Internet Service Providers Austria…

Austrian public service group seeks simpler GDPR rules

Verband der öffentlichen Wirtschaft und Gemeinwirtschaft Österreichs, 8 Feb 2024

The organization requests exemptions for pseudonymized data and clearer definitions for excessive access requests. They also propose adding operational necessity as a legal basis for processing public service data.
This would reduce administrative costs and protect utilities from simplifying complex technical records.
Data subjects would receive less accessible information and face limits on frequent access requests.

Consultation response

Europeans for Safe Connections, 2 Feb 2024

Herein enclosed you'll find our feedback Best regards

Consultation response

Media Scope Group OÜ, 30 Jan 2024

Please find attached the feedback for the Report on the General Data Protection Regulation.