EDPB Guidelines 4/22 on the calculation of administrative fines under the GDPR
Bitkom welcomes the opportunity to comment on the European Data Protection Board´s Draft Guidelines on the calculation of administrative fines under the GDPR (Guidelines 04/22). We believe that more cooperation and exchange between data protection authorities and practitioners is needed to translate the legal text of the GDPR into practice and reduce legal uncertainty.
The legal uncertainties regarding the implementation of the GDPR continue to pose problems in the market. Even with regard to the sanctions that can be imposed for violations of the GDPR, there is still no uniform application or understanding. We therefore welcome that the EDPB is trying to harmonise the approach throughout the EU.