By David Barnard-Wills, 19 January 2017
The PHAEDRA II project, in which Trilateral Research has been a partner, came to a successful conclusion in January with the publication of its final recommendations.
PHAEDRA II was the continuation of the previous PHAEDRA project. Both projects worked with the international and European networks of data protection and privacy enforcement authorities to support their increased collaboration on increasingly international issues, and such as cross border flows of data, joint investigations, and the effective protection of privacy and data protection rights. PHAEDRA II focused upon the changes brought about by the new European data protection framework, which places new obligations upon European DPAs to work together.
Our work on the projects included policy and regulatory analysis, interviews and stakeholder research, case study research and strategic recommendations. It has been a particular pleasure to work on a research project so closely linked to its audience as this one.
The final recommendations from the project, addressed to that audience, are:
1. Recognise the fundamental equality of supervisory authorities
2. informal mechanisms for cooperation should supplement formal ones – trust is a key enabling factor.
3. Cooperation should reflect national differences, but also allow for some extraterritoriality where appropriate.
4. Cooperation should have as broad a geographical scope as possible
5. Cooperation should be developed gradually and its functioning should be reviewed periodically.
6. Decide how to share the costs of cooperation.
7. Keep translation to a minimum while dealing with individual cases, maximise translation in guidance and public communications.
8. Cooperate on the development of policies and practices to prevent data privacy violations.
9. Set up a collaborative technology foresight task force. Offer research funds to that end.
10. Explore alternative dispute resolution methods.
The rationale for each of those, but as well as the research and evidence base supporting them, and more granular recommendations on specifics such as complaint handling, the consistency mechanisms and IT platforms, are set out in more detail in the report itself, and available from phaedra-project.eu/
In addition to the final recommendations, the PHAEDRA II wrap up included reports on its meetings and events, a summary of all the articles published on the project blog, as well as a study report looking over the repository of key DPA decisions built by the project.