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2.5 Stronger Institutional Arrangements For Better Enforcement


We have been campaigning for a long time for enhanced powers for the Information Commissioner in the UK, and therefore welcome the intention in the Communication to both strengthen the roles of the Data Protection Authorities (DPA), and the co-operation between them.  We ask that there is greater harmonisation of standards for DPAs powers and particularly for their independence both material and in terms of who they answer to. We believe they should be answerable to Parliament rather than particular government policy departments. This would ensure both greater transparency and accountability to the public at large. We also believe that the appointment process should be considered within this review.

We would also support enhancing the role of Article 29 Working Party as a means to ensuring greater consistency within the EU. In particular its Opinions should take the form of Guidance to be adopted both in the Commission proposals and by DPAs on national levels.


We support the proposed next steps and look forward to discussions and co-operation with the Commission, the Parliament and the Council on the detail of the proposed framework.