Managing Data Archives

ACCIS response to EDPB’s Guidelines on calculation of fines

Jun 27, 2022 | Managing Data

In our response to the EDPB’s Guidelines on calculation of fines, we note that the EDPB appears to emphasise setting GDPR fines at a level that effectively deters future non-compliance whilst we would prefer similar attention to ensuring the proportionality of GDPR...

ACCIS feedback on the European Commission’s proposal on the EU Data Act

May 30, 2022 | Managing Data

In our feedback document on the proposed EU Data Act, ACCIS broadly welcomes the EU Data Act as it creates a fairer, more innovative, and more competitive data economy in Europe. We are however unclear as to the stated harmonising objective of the Regulation. The GDPR...

ACCIS feedback on a proposal establishing a European Single Access Point

Mar 28, 2022 | Managing Data

In our response, we highlight that the proposal offering a single point of access to public information about EU companies and EU investment products could potentially allow ACCIS members to retrieve and process data which is used for added value services (e.g.,...

ACCIS response to EDPB’s Guidelines 01/2022 on Data Subject Rights – Right of Access

Mar 11, 2022 | Managing Data

In our response to the EDPB’s Guidelines 01/2022 on Data Subject Rights – Right of Access, we highlight several positive elements in how the EDPB guides in relation to the form of Data Subject Access Requests (DSARs), the provision of a copy or the limits to respond...

ACCIS response to the public consultation on the future EU Data Act

Sep 2, 2021 | Managing Data

In our response to the public consultation on the future EU Data Act, ACCIS describes the data sharing activity of CRAs. Regarding the most relevant elements to increase data sharing, ACCIS agrees with the basic idea that the party sharing data obtains a reasonable...

ACCIS letter on Guidelines 10/2020 on restrictions under Article 23 GDPR

Feb 11, 2021 | Managing Data

In this letter to the European Data Protection Board, ACCIS recalls that – whilst the draft guidelines do not exclude the application of restrictions for the benefit of private entities and for private interests – the examples provided in the draft guidelines do not...