15 March 2023 - The European Data Protection Board (EDPB) launches today the second coordinated supervisory action of data protection authorities, which will focus this year on the designation and position of Data Protection Officers (DPOs).
As intermediaries between data protection authorities, individuals and organisations, DPOs play an essential role in ensuring better compliance of organisations with data protection law and in promoting effective protection of data subjects’ rights.
The coordinated enforcement action (CEF) for 2023 involves 26 data protection authorities from the European Economic Area (EEA), including the CNPD. The main objective of this year’s CEF is to learn more about the role played by DPOs in organisations, whether they hold the position required by Articles 37 to 39 of the GDPR and whether they have the necessary resources to carry out their tasks.
This action is done through a common matrix questionnaire so that the responses obtained are analysed in a coordinated manner and the results aggregated and subject to a final report by the EDPB.
At national level, the CNPD will contact directly, during the next week, DPOs notified to the Commission by all public and private organisations to participate voluntarily in this action and to reply to the CEF 2023 questionnaire.
This will not be an investigative action, as the CNPD first wants to have a deeper understanding of the role of DPOs in organisations so that it can also find ways to better support their work. In this respect, it is of utmost importance, and also in the interest of DPOs, that they have a strong involvement in the response to this questionnaire. To ensure a higher response rate, the DPO does not have to provide his/her identification nor to identify the organisation concerned.
In 2022, when the first CEF action took place, the topic of election was the use of cloud based services by the public sector, in which the CNPD also participated. A report on the results of this CEF initiative, containing recommendations for public authorities, was adopted by the European Committee in January this year.
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