Is the Art29 Working Party Undermining Itself?

As the application date of the General Data Protection Regulation (“GDPR”) draws near, the Article 29 Working Party (“WP”) continues to produce guidelines on various key concepts and requirements. While these guidelines are largely helpful, they contain some questionable views that arguably amount to the WP purporting to make, as opposed to interpret, the law.  By overreaching, the WP risks undermining its own credibility and giving organisations an excuse to decline to follow elements of its guidelines as being activist statements of policy rather than legal requirements.

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