TL;DR for the DPO
The EDPB announced its 2026 Coordinated Enforcement Action focuses on TRANSPARENCY and information obligations (Art. 12-14 GDPR). National authorities will jointly examine privacy notices: clarity, completeness, accuracy. Previous themes were the DPO role and access/erasure rights.
What they will look at
- Plain language: is the notice understandable or a wall of legalese?
- Completeness: all Art. 13-14 elements (purposes, legal bases, retention, rights)?
- Extra-EU transfers: some authorities expect EACH third country to be explicitly named
- Accessibility: easy to find and read, including on mobile?
What to do now
Time for a notice review across your clients. For special-category sectors (e.g. healthcare) the bar is higher: separate notices by data-subject category (patients vs staff).
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