In preparation for requirements in Article 97 of the EU General Data Protection Regulation, a host of member state delegations submitted comments to the Council of the European Union on their evaluation and review of the application of the GDPR. In all, 19 member states commented in a 72-page document released Oct. 9. Of course, there's a lot in there to chew on, but IAPP Senior Westin Fellow Müge Fazlioglu, CIPP/E, CIPP/US, has gone through the comments to assess how member states regard the application of the GDPR so far. Article 97 "has already prompted member states, supervisory authorities and other European institutions to deeply reflect upon the problems, obstacles and hindrances to the GDPR’s implementation and to share and discuss their observations and experiences with its application since it came into force last year," she writes. In this post for Privacy Perspectives, Fazlioglu offers her thoughts on the member state commentary and why privacy pros should pay attention to the process moving forward.
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