GDPR Article 75 — Secretariat

What this control requires

Establish a secretariat under the European Data Protection Supervisor to support the Board with analytical, administrative, and logistical tasks, operating under the Chair's instructions. Ensure separate staff reporting lines, a published Memorandum of Understanding, and manage communications, translations, and preparation of Board opinions and decisions. This control addresses Remedies, Liability and Penalties.

In plain English

Establish a secretariat under the European Data Protection Supervisor to support the Board with analytical, administrative, and logistical tasks, operating under the Chair's instructions. In practice, this means you can prove you data board-level controls on a defined cadence.

Why it matters

GDPR administrative fines reach the greater of €20 million or 4% of global annual turnover. The European Data Protection Board (EDPB) coordinates supervisory-authority enforcement across the EU/EEA, and DPAs publish enforcement decisions citing specific Articles.

What an auditor looks for

A DPA or privacy auditor expects: a Records of Processing Activities (RoPA) entry, a documented lawful basis, evidence the Article's data-subject right is operationalised end-to-end, a named DPO contact (where required), and Article 30 records that match what the front-end actually does.

Within Chapter VIII: Remedies, the assessor will trace your implementation back to the catalogue reference (Article Article 75) and look for objective evidence on the latest two assessment cycles.

How to implement

Secure Development

Pipeline. Require code review, SAST (Semgrep / Snyk Code), SCA (Dependabot / Renovate), secret-scanning and IaC scanning in the merge pipeline.

Branch protection. Protected branches enforce reviews, signed commits and passing CI before merge; document the protection rules as the control evidence.

Code Review Testing

Pipeline. Require at least one human reviewer plus passing CI (lint, type, unit, security scan) before merge — protected branches enforce this.

Operational checklist

• Data. Document the trigger, the owner and the cadence.
• Tasks. Document the trigger, the owner and the cadence.
• European. Document the trigger, the owner and the cadence.
• Chair. Document the trigger, the owner and the cadence.
• Secretariat. Document the trigger, the owner and the cadence.
• Scope: board, chair.

Evidence to collect

• Code Repo Scan. Source-control evidence — branch protection, required reviewers, CI status, SCA / SAST reports.

Source control pipelines (GitHub, GitLab) enforce SDLC guardrails. Focus: Secretariat.

Common pitfalls

• CI security checks set to warn-only; the merge button is faster than the security feedback.

How it maps to other frameworks

Computed from shared tags, control component and key-operation subjects — handy when you are reconciling controls across an audit.

• CIS Controls v8 14.6 — Train Workforce Members on Recognizing and Reporting Security Incidents
• SOC 2 (2017 TSC) CC7.2 — Anomaly Detection
• BSI C5:2020 OPS-03 — Capacity Management - Controlling of Resources
• ISO/IEC 27001:2022 A.8.31 — Separation of development, test and production environments

Related controls in GDPR

• Article Article 73 — Chair
• Article Article 74 — Tasks of the Chair
• Article Article 41 — Monitoring of approved codes of conduct

References

• European Union — GDPR
• Catalogue identifier: Article Article 75

Topics: governance risksecure developmentcode review testingdevsecops