EDPB & EDPS issue joint statement on GDPR simplification proposal

09/07/2025 | EDPB

The European Data Protection Board (EDPB) and the European Data Protection Supervisor (EDPS) have issued a joint statement concerning the European Commission's draft proposal on the simplification of record-keeping obligations under Article 30(5) of the EU General Data Protection Regulation (GDPR). The EDPB and EDPS support reducing the administrative burden for smaller businesses, provided it does not diminish the fundamental right to data protection.

The EDPB and EDPS welcome the targeted and limited nature of the proposed modifications, noting they do not affect core GDPR principles. However, they stress the importance of proportionality and necessity in simplification, citing the absence of a fundamental rights impact assessment in the proposal. 

To avoid misunderstanding, the EDPB and EDPS suggest an amendment to the recitals that would make records of processing mandatory only for high-risk activities covered under Articles 9 and 10 of the GDPR. To this end, they propose rephrasing Recital 10 to ensure that processing for purposes under Article 9(2)(b) would not require record-keeping unless the processing is likely to result in a high risk.

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Records of Processing Activities, RoPA, audit, privacy management

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