The European Data Protection Board (EDPB) has announced that its 2023 coordinated enforcement action under the Coordinated Enforcement Framework (CEF) will focus on the designation and position of data Data Protection Officers (DPOs). In 2023, the CEF will address the designation and position of DPOs within their organisation, including whether they have the necessary resources to carry out their duties under Articles 37-39 of the EU General Data Protection Regulation (GDPR). The EDPB confirmed that 26 Data Protection Authorities (DPA) and the European Data Protection Supervisor (EDPS) would participate.
In describing the importance of the role of the DPOs, the EDPB said, “As intermediaries between DPAs, individuals and the business units of an organisation, data protection officers have an essential role in contributing to compliance with data protection law and promoting effective protection of data subject rights.”
In the first instance, the coordinated action involves sending DPOs questionnaires to identify whether a formal investigation and further follow-up activities are required. The EDPB will analyse the results in a "coordinated manner" with possible further enforcement action taken by DPAs at the national level, along with targeted follow-up at the EU level, ahead of a final report.
The IAPP provides additional details on the CEF 2023 and what to expect as the process develops. The EDPB's announcement follows last week's IAPP post about what to expect under the CEF targeting DPOs.
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