Inside the Belgian DPA management plan for aligning sanctions with EDPB fine rules

One of the tidbits in the Belgian Data Protection Authority’s “Management Plan 2024”: “Setting a sanctions policy, taking the EDPB’s guidelines on fines into account” (action point for 2024 for the Litigation Chamber).

Interestingly for the broader question of the legal value of EDPB guidelines, this sanctions policy is described elsewhere in the document as being “for implementation of the EDPB’s guidelines”, using the word “uitvoering” in Dutch and “ex�cution” in French (which in contractual terms would be “performance” – i.e. “in accordance with”).
Who knows, I may soon need to make jurisdiction-specific versions of www.khlaw.com/define !

Some other tidbits:

– The Knowledge Centre hopes to publish recommendations in 2024, including one on “the criteria to be taken into account when selecting trusted third parties responsible for anonymising or pseudonymising data (before, for example, making it available in an open data context)
– The Inspection Service “foresees that it will further generalise the technique of hearings [= interviews] and of the on-premise visit [= dawn raids]
– The Inspection Service hopes to do more investigations on its own initiative (“ex officio” investigations).

Link to the document:
– in French: https://lnkd.in/eKZYcHpD
– in Dutch: https://lnkd.in/eQ223rNU

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