Overview
This article assigns the Chair of the European Data Protection Board (EDPB) responsibilities for convening Board meetings, preparing agendas, notifying decisions under Article 65 to relevant supervisory authorities, and ensuring the timely execution of Board tasks, particularly within the consistency mechanism outlined in Article 63. Tasks may be allocated between the Chair and Deputy Chairs according to Board rules.
Key Principles
Leadership and Coordination: Chair convenes meetings and ensures proper execution of Board tasks.
Agenda Preparation: Responsible for setting agendas and prioritizing matters for discussion.
Decision Notification: Communicate decisions under Article 65 to supervisory authorities.
Consistency Oversight: Facilitate the consistency mechanism (Article 63) for cross-border GDPR enforcement.
Task Allocation: Deputize responsibilities to Deputy Chairs as appropriate under Board rules.
Organizational Applicability
This article applies to:
The Chair and Deputy Chairs of the EDPB.
Board Secretariat and support staff managing meetings, communications, and coordination.
Supervisory authorities receiving notifications and participating in cross-border consistency processes.
Implementation Requirements
Convene Board meetings and ensure quorum for decision-making.
Prepare and distribute meeting agendas to members and relevant stakeholders.
Notify supervisory authorities of decisions under Article 65 promptly.
Oversee tasks related to the consistency mechanism (Article 63).
Allocate responsibilities between Chair and Deputy Chairs in line with Board rules.
Implementation Guidance
Maintain a meeting schedule and procedural checklist for Board tasks.
Train Chair, Deputy Chairs, and Secretariat staff on task management and notification protocols.
Implement a system for tracking decisions, notifications, and consistency mechanism actions.
Periodically review task allocation and procedural effectiveness.
Periodic Review
Frequency: Annually or when changes in leadership, Board rules, or processes occur.
Responsible Role: EDPB Chair, Deputy Chairs, Secretariat.
Outcome: Ensure Board tasks are executed efficiently, notifications are timely, and cross-border consistency is maintained.
Non-Compliance Risks
Fines: Up to €20 million or 4% of global annual turnover for supervised entities.
Legal Exposure: Challenges due to delayed notifications or improper execution of Board tasks.
Reputational Damage: Loss of confidence in Board leadership and consistency in GDPR enforcement.
Operational Risk: Ineffective coordination may hinder cross-border decision-making and timely implementation of Board actions.