Key Provisions subgroup meeting
07 September 2018, EDPB premises, 30 Rue Montoyer, 1000 Brussels
Introduction & organisation of work
Welcome & introduction
The coordinators welcomed the participants and a tour de table has been done.
Approval of the Agenda
The draft agenda was approved.
Dates for the next meetings
The date for the next Key Provisions subgroup is the 8th of November
. The meeting dates for
January and February stil need to be defined.
Information from the Secretariat
The secretariat informed the participants that
together in charge of this subgroup for the EDPB Secretariat.
Guidelines on the application of the territorial scope of the GDPR
Discussion on the updated version of the draft paper
The Lead Rapporteur presented the changes introduced to each section of the draft guidelines.
Members were requested to submit comments to the rapporteur in light of the discussions. Said
comments wil then be transmitted to the FOP subgroup.
Reorganisation of the EDPB subgroups
Short exchange of views
Fol owing a short exchange of view on the reorganisation of the EDPB subgroups, the members
the name of the subgroup should be kept;
the subgroup should have exclusive competence on matters relating to chapters I and I and
it wil cooperate with other subgroups on core notions of the GDPR on matters relating to
chapters I I, IV and IX;
the subgroup should focus on legislative proposals related only to its competences;
the subgroup should ensure the fol ow-up of guidelines related only to the subgroup
The members discussed the Coordinator’s proposal to request a new mandate for the update of the
guidelines on control er / processor, focusing in particular on the issue of joint control ership. The
members agreed to reopen the discussion on a new mandate during the November meeting.
Position Paper on the lawful basis for processing under Article 6(1)(b)
in the context of the provision of online services to consumers
Discussion on the draft of the position paper
The subgroup members discussed the draft, in particular specific examples of processing in online
services. It was agreed that written comments should be submitted until the 24th September, with
the aim of having the paper circulated to the co-rapporteurs on the 8th October and to all members
on the 25th October.
Next steps / To-do
1. Members may send comments on: - the guidelines on territorial scope of the GDPR by 10
in view of its submission to the FOP and to the Plenary (on 17 September
- the position paper on reliance on Article 6(1) (b) in the context of ‘free’ online services (by 24
2. The guidelines on territorial scope wil be submitted to the FOP subgroup and to the Plenary.
Annex: List of Attendance
EDPS (coordinator), AT, BE, CZ, DE (Anspach), DE (Federal), DE (Nordrhein-Westfalen SA), DE (ULD
Schleswig-Holstein), DK, EL, ES, FR, HR, HU, IE, LU, LV, NL, PL, RO, SE, SI, UK, IT, PT