ACCIS response to the EDPB’s Guidelines 1/2024 on processing of personal data based on Article 6(1)(f) GDPR – Legitimate interest
In our response to the EDPB Guidelines on legitimate interest, we highlight areas of agreement as well as sections where further clarification or amendment may be beneficial to ensure a balanced application of legitimate interest provisions in the context of consumer...
ACCIS response to the European Commission’s call for evidence on the GDPR
In this response, we express concerns about perceived imbalances in GDPR enforcement. We also note that the absence of clear guidance exacerbates the situation, especially in cases where the GDPR falls short in providing necessary clarity. Members of ACCIS assert that...
ACCIS statement on several CJEU cases
In this statement, we outline our views on several CJEU cases that can shape the regulatory framework for the provision of credit referencing services in the internal EU market. In our opinion, cross-border access to credit databases will only be meaningful if the...
ACCIS response to EDPB’s Guidelines on calculation of fines
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
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...