EBF’s comments to the Working Party 29:
EBF advisor: Noémie Papp
Publication date: 15 February 2017
The EBF welcomes the possibility given to provide comments on the Guidelines prepared by the Article 29 Data Protection working party (Article 29 WP) on the Data Protection Officers (DPOs).
The response focuses specifically on ‘Easily accessible from each establishment’ (2.3)
As a general comment, we believe that further consideration should be given to the principle of proportionality as the proposed guidelines could potentially be very burdensome especially for the smaller banks.