Comments on the draft of the EDPB “Guidelines 03/2021 on the application of Article 65 (1)(a) GDPR”

Comments on the draft of the EDPB “Guidelines 03/2021 on the application of Article 65 (1)(a) GDPR”

In general, we would like to point out that it could be very helpful to explain why the EDPB has decided to incorporate certain procedural provisions directly related to its activities into these guidelines, instead of being part of the binding Rules of Procedure under Article 72 (2) of the GDPR.