On 5 October 2012, the Article 29 Working Party adopted Opinion 8/2012 providing further input on the data protection reform discussions. One of the issues discussed was whether all provisions allowing the Commission to adopt delegated and implementing acts were actually justified and needed. In the Annex to Opinion 8/2012, the Working Party presented an Article-by-Article analysis of all provisions on possible delegated acts. The provisions on implementing acts were then left aside. The current additional input focuses on these implementing acts.
The Working Party begins by dealing with the differences between delegated and implementing acts as indicated in Opinion 8/2012. The relevant criteria for determining the justification and need of implementing acts are then listed. Finally, an Article-by-Article assessment of all possible implementing acts is provided.
The document can be viewed in full here (25-page pdf).
