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Responding to EDPB Consultation


SCOPE Europe and SRIW provided their joint comments on the EDPB Guidelines 04/2022 on the calculation of administrative fines.

SCOPE Europe and SRIW appreciate the opportunity to share our views in the context of this public consultation which we consider to be a crucial exercise to optimize and harmonize data protection practices across the EU.

We believe the Guidelines are an essential piece of orientation, fostering harmonization in the methodology used by supervisory authorities to calculate fines and, therefore, playing a crucial role in ensuring that key administrative and democratic principles such as predictability and legal certainty are maintained.

We highly welcome these Guidelines and are pleased to share our insights and suggestions as organizations specialized and largely experienced in the fields of co and self-regulation. In this context, we recommended that certain elements regarding the legal benefits of codes of conduct to be made clearer and more detailed. In order to learn more about our input, please read the full response via the link below.