Recital 72

Go to related Article 33

Commission proposal

(72) There are circumstances under which it may be sensible and economic that the subject of a data protection impact assessment should be broader than a single project, for example where public authorities or bodies intend to establish a common application or processing platform or where several controllers plan to introduce a common application or processing environment across an industry sector or segment or for a widely used horizontal activity.

EDRi’s Proposed amendment

(72) There are circumstances under which it may be sensible and economic necessary that the subject of a data protection impact assessment should be broader than a single project, for example where public authorities or bodies intend to establish a common application or processing platform or where several controllers plan to introduce a common application or processing environment across an industry sector or segment or for a widely used horizontal activity.

Justification
This proposed text clarifies that such an approach should be considered necessary where there are wider technical challenges to the protection of the data in question.

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