On Dec. 13, the Dutch government introduced its GDPR Implementation Bill to the Parliament. Jeroen Terstegge, CIPP/E, CIPP/US, offers an overview of the bill in this Privacy Tracker post, noting that while there are few surprises, "some improvements are necessary." Terstegge writes that the bill includes a huge incentive for organizations to appeal fines, stating that "a decision cannot be enforced as long as it is subject to review and judicial appeal." The likely result being that the data protection authority will use "administrative orders under penal sum as their primary enforcement instrument." Along with the bill, the Dutch State Council published advice stressing the need for clarity under the GDPR and highlighting concerns over transparency and accountability with decisions made by the European Data Protection Board.
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