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SCOPE Europe (Self and Co-Regulation for an Optimized Policy Environment in Europe)

SCOPE Europe

SCOPE Europe is a Brussels-based organization specialized in the development and implementation of industry-driven standards, such as codes of conduct, with a focus on the data economy.

Lobbying Activity

Response to Report on the application of the General Data Protection Regulation

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.
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Response to Further specifying procedural rules relating to the enforcement of the General Data Protection Regulation

24 Mar 2023

Please, find the detailed joint-feedback as attachment. Following the key messages: 1. It is strongly recommended to extend the understanding of enforcement by integrating complementing tools, such as Codes of Conduct, into the evaluation by the European Commission. Codes of Conduct strongly support harmonization across Europe, by allowing for particularizing ambiguous interpretations in sector-specific manners. The enforcement of Codes of Conduct complements the public actions via data protection supervisory authorities and may significantly increase GDPR compliant yet practical implementations. Compulsory oversight by independent Monitoring Bodies allows for additional robust enforcement. Required continuous communication between Monitoring Bodies and data protection supervisory authorities may establish exchange of first-hand experiences, fostering consistent, robust yet practical application of the law. 2. It is strongly recommended to review the procedural requirements in receiving a Code of Conducts approval and a Monitoring Bodys accreditation. Generally, the legal framework and EDPBs guidelines are considered suitable, if applied consistently. Specifically for transnational Codes of Conduct, harmonized interpretation is appreciated, because projects suffer delays, e.g., by means of consistently and mutually determining the competent data protection supervisory authorities. Periods as indicated by GDPR are not yet met in practice. So, it is recommended to adapt such periods to more realistic timelines and to clarify that in case data protection supervisory authorities cannot unanimously determine undisputable conflicts with GDPR, Codes of Conduct shall be deemed in accordance with GDPR. It is recommended to limit deviations in regards of the accreditation criteria for Monitoring Bodies to the minimum needed, e.g., by different administrative member state laws. Any material deviation creates unnecessary obstacles to Monitoring Bodies, which seek to provide their services in several member states, limiting the scalability of their services, which is a key element in ensuring that adherence to Codes of Conduct remains accessible to micro, small and medium sized enterprises. 3. In regards of third country transfers, a general validity by implementing act is required. It is strongly recommended to ensure that procedural efforts will be streamlined preventing any unreasonable delays in operationalizing such projects. Safeguarding third country transfers is one of the key elements subject to legal, political and operational discussions. Codes of Conduct may act as a safeguard provide that, next to the formalities to be met for transnational Codes of Conduct in any case, general validity will be granted. Considering the procedural steps of deciding on an implementing act, it is strongly recommended to allow for a material assessment by the European Commission and the EDPB in parallel.
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Response to Commission Implementing Decision on standard contractual clauses for the transfer of personal data to third countries

10 Dec 2020

We appreciate the chance to provide comments on the new standard data protection clauses for the transfer of personal data to third countries pursuant to Article 46 GDPR. We acknowledge the great value of the updated framework, which will help companies when relying on third country transfers and hope our detailed comments may contribute to the further enhancement of the SDPC. Also, we look forward to further contributing to the related developments.
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Meeting with Geneviève Tuts (Cabinet of Commissioner Didier Reynders), Lucrezia Busa (Cabinet of Commissioner Didier Reynders)

5 Jun 2020 · Scope informed us on the current state of play of the development of Codes of conducts