Magdalena Gad-Nowak of Squire Patton Boggs writes:
On July 8, 2019 the updated list of operations requiring a data protection impact assessment (DPIA) was published in the official gazette of the Republic of Poland. The “black list” was updated by the Polish data protection authority, after the European Data Protection Board (EDPB) raised its objections to the original draft published by the Polish regulator on August 17, 2018. According to the EDPB’s opinion 17/2018, the original “black list” could have led to inconsistent application of the requirement for a DPIA and, therefore, should be subject to modifications.
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