Abstract

Upon request of the Article 29 Working Party [in which the European Data Protection Authorities (DPAs) are assembled], the French Data Protection Authority, CNIL, led an investigation into Google’s new privacy policy that was followed by the DPAs publishing their common findings in October 2012. The recommendations, several of which are also supported by DPAs from other regions of the world, urged Google to take effective and public measures to update its privacy policy. This was the first co-ordinated action of this kind undertaken by European DPAs. This Chapter analyses several joint investigations by European and other DPAs. What are the common features of co-ordination and co-operation, what lessons can be learned, what best practices emerge? The results of joint investigations are set against future challenges in confronting big multinationals in regard to the new EU Data Protection Regulation. Several elements of the draft Regulation are examined, notably the consistency mechanism. Finally, suggestions are made to optimise future co-operation and co-ordination by the European DPAs.

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