NGO Involvement in the Evaluation and Follow-Up Mechanisms for Data Protection Convention 108+ (Submission to the Consultative Committee of Data Protection Convention 108 by the Australian Privacy Foundation (APF), the Electronic Privacy Information Center (EPIC) and Privacy International (PI))

Abstract

Three NGOs specialising in privacy issues, the Australian Privacy Foundation (APF), the Electronic Privacy Information Centre (EPIC) from the US, and the UK-based Privacy International, have made a joint submission to the Consultative Committee of data protection Convention 108, concerning the proposed Evaluation and Follow-Up Mechanism for the new 'modernised' version of the Convention (usually called 'Convention 108+). The submission give strong support to the comprehensive and valuable recommendations contained in the proposals, and suggests expanded NGO involvement in the proposed evaluation and follow-up mechanisms. In particular, the Submission proposes involvement of NGO nominees in Working Groups of the new Convention Committee, for the additional perspectives they can bring. Among fourteen s suggestions, others concern transparency of processes, the order of evaluation of Convention Parties, the evaluation criteria, and participation in Committee discussions of particular evaluations. The Evaluation and Follow-Up Mechanism will be discussed at the Consultative Committee's next Plenary Meeting in Strasbourg in November 2019.