Mapping the supervisory authorities’ activities: Pragmatic problem-solvers or new practice creators?

Abstract

Data protection supervisory authorities (SAs) have a prominent role to play in the new architecture of the European Union’s (EU) data protection landscape. What do their articulations tell about data protection matters? Can we predict some trends or patterns from their activities? These are the questions underpinning this paper, which maps out the role of SAs in the European data protection landscape, both in terms of what the EU’s General Data Protection Regulation prescribes for them and some of the statements made or actions taken recently by SAs. This paper aims to identify some main — ongoing and emerging — trends of the different SAs. It then analyses whether SAs are addressing issues in a continuum with the practices so far in place or, in effect, creating new practices.