EDPB: Launch of coordinated enforcement on role of data protection officers.

The European Data Protection Board has kicked off its 2023 coordinated enforcement action. Throughout the year, 26 Data Protection Authorities (DPA) across the EEA (including EDPS) will take part in the CEF 2023 on the designation and position of data protection officers (DPOs).

As intermediaries between DPAs, individuals and the business units of an organisation, data protection officers have an essential role in contributing to compliance with data protection law and promoting effective protection of data subject rights.

To gauge whether DPOs have the position in their organisations required by Art. 37-39 GDPR and the resources needed to carry out their tasks, participating DPAs will implement the CEF at national level in a number of ways:

1. DPOs will be sent questionnaires to aid fact-finding exercise or questionnaires to identify if a formal investigation is warranted;
2. commencement of a formal investigation;
3. follow-up of ongoing formal investigations.

The results of the joint initiative will be analysed in a coordinated manner and the DPAs will decide on possible further national supervision and enforcement actions. In addition, results will be aggregated, generating deeper insight into the topic and allowing targeted follow-up at EU level. The EDPB will publish a report on the outcome of this analysis once the actions are concluded.

This series of actions is the second initiative under the Coordinated Enforcement Framework (CEF). CEF initiatives aim to streamline enforcement and cooperation among Data Protection Authorities (DPAs).