Overview
This article establishes that each supervisory authority is competent to perform GDPR-related tasks and exercise powers within its own Member State. Certain exceptions apply, including courts acting in a judicial capacity and specific processing activities carried out by public authorities or private bodies as defined under GDPR.
Key Principles
Territorial Competence: Supervisory authorities operate within the jurisdiction of their Member State.
Task Authority: Authorities have the power to monitor and enforce GDPR compliance locally.
Exceptions: Judicial bodies and certain public or private processing activities may fall outside the authority’s competence.
Accountability: Authorities must act within their legal and territorial scope while ensuring compliance.
Organizational Applicability
This article applies to:
Supervisory authorities established in each EU Member State.
Controllers and processors subject to the authority’s oversight within the Member State.
Teams managing compliance, enforcement, and local GDPR regulatory actions.
Implementation Requirements
Define the scope and limits of the supervisory authority’s powers.
Establish procedures for exercising authority over controllers and processors within the Member State.
Identify exceptions for courts and specific processing activities.
Maintain documentation of jurisdictional boundaries and responsibilities.
Implementation Guidance
Clearly communicate the authority’s competence and limits to organizations and stakeholders.
Coordinate with other Member State authorities where cross-border processing is involved.
Train staff on jurisdictional rules, exceptions, and enforcement powers.
Periodically review and update competence policies to reflect regulatory or organizational changes.
Periodic Review
Frequency: Annually or when changes in jurisdiction, law, or processing activities occur.
Responsible Role: Supervisory authority leadership, Compliance Team, or Legal.
Outcome: Ensure clarity of competence, proper enforcement within scope, and recognition of exceptions.
Non-Compliance Risks
Fines: Up to €20 million or 4% of global annual turnover for supervised entities.
Legal Exposure: Challenges to authority actions outside its competence.
Reputational Damage: Loss of trust due to overreach or misapplication of authority powers.
Operational Risk: Misunderstanding competence boundaries may affect enforcement and cross-border coordination.