Opinion of the Data Protection Officer on General Personal Data Processing Implementing Rules

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Opinion of the Data Protection Officer: General Personal Data Processing Implementing Rules (Reg. No 13609, 3 December 2021, pdf)

In their opinion, the DPO states that “the obligation of consultation “properly”, as mandated by the DPR [presumably the Data Protection Regulation], has not been followed”. DPO also “considers that these rules are not yet mature for presenting to the Management Board, and that more drafting is necessary for clarification and completion purposes."

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