EDPB Support Pool of Experts: enhancing cooperation by complementing the strengths of SAs

During its December plenary, the European Data Protection Board adopted a project plan for its Support Pool of Experts. We spoke with Gwendal Le Grand, the driving force behind this pilot project.

What is the Support Pool of Experts? And why did the EDPB launch this initiative?

The Support Pool of Experts (SPE) is one of the key initiatives within the EDPB 2021-2023 Strategy. We are now 3 and half years into the application of the GDPR. While the enforcement of the GDPR has led to more than 300 resolved cross-border cases, it remains essential to enhance cooperation by complementing the strengths of individual Supervisory Authorities (SA). It is natural that a single SA does not always have all the expertise in-house to deal with any given enforcement area. Together, however, they have a great deal of expertise. We want to build upon this idea and support individual SAs in building and increasing their capacity to enforce by developing common tools and giving them access to an EEA-wide pool of experts. We are convinced that the SPE will strengthen the common enforcement culture.

Can you reveal anything about the SPE’s upcoming work?

The SPE will be involved in a wide range of activities. Our initial focus will be on making sure enough resources are available for the SPE to work well. This will, of course, involve sharing expertise between SAs, and to complement the EDPB-wide know-how, we will probably also launch a call for external experts. We will help SAs to provide assistance to each other in solving concrete cases and we will develop common standards or toolboxes that can be used for inspections, and train SAs to these standards. Finally, we will set up a workshop for the Heads of the SAs to discuss the enforcement strategy. In addition, we will continue to share information on national administrative and procedural laws, as this has an important impact on enforcement. Greater transparency in this area will not just benefit SAs, but also businesses and individuals. The same goes for national case law, on which we will also exchange information. It is important for SAs to know what has been decided in another Member State with regard to a certain enforcement area. 

In 2020, the EDPB also established the Coordinated Enforcement Framework (CEF). How is the Support Pool of Experts related to the Coordinated Enforcement Framework and what is the role of the EDPB in both initiatives?

The SPE and CEF are two closely related initiatives which complement each other. The ultimate goal of both programmes is also the same, namely sharing experience and fostering convergence in enforcement practices. Both initiatives aim to provide practical solutions for better enforcement by creating synergies. The SPE is a horizontal and overarching pilot programme led by the EDPB. The CEF is more operational. Each year, the SAs agree upon a common enforcement topic and establish annual coordinated actions.

What further action can we expect from the EDPB on this front?

In the first quarter of 2022, we will announce further details on the first topic that was chosen for coordinated action within the CEF, namely the use of cloud services by the public sector. The EDPB prioritised this topic because the increasing deployment of cloud services in the public sector triggers a number of data protection risks which require careful assessment.