The GDPR has been in force for less than two years, but we are
already observing its effect on data subjects, data
controllers/processors, and data privacy regulators. A huge,
complex set of societal regulations is bound to have problematic
passages and unintended consequences. So it seems time to begin
consideration of how to revise the law for efficiency,
effectiveness, and policy.
In November 2019, German data privacy authorities released a
report noting the problems they encountered implementing GDPR and
proposing changes to the law. The Report could be the first formal
proposal in an effort to amend the EU Privacy laws.
The Report on Experience Gained in the Implementation
of the GDPR [link to English translation] is a product of both
the Federal and State Data Protection Supervisory Authorities in
Germany, known as the Datenschutzkonferenz or DSK. The report is a
wish list for privacy law revisions by one set of that law's
primary enforcers.
