Side by side
Consultation participation and their own register declarations, side by side. Counts, not judgments — participation is not influence.
Counts here are a floor, never a total: they cover the 583 consultation files tracked so far (42,224 submissions, mostly 2025–26), so an organization's real filing history is larger, not smaller.
Academic / research · Norway
Company · Germany
Declared costs: €2M+ a year · in the register since 2015
Commission Implementing Decision on standard contractual clauses for the transfer of personal data to third countries · Commission Implementing Decision on standard contractual clauses between controllers and processors located in the EU
Register facts self-declared (snapshot 2 Sept 2026); cost bands are floors. Shared files are shared attention, not evidence of coordination.
Their opening passages on the files they share, verbatim and in filing order. We do not summarize, compare, or characterize positions — read them at source.
Norwegian Institute of Public Health · filed 10 Dec 2020 · source
Dear Commission, Please find attached our feedback on the draft Data protection - standard contractual clauses for transferring personal data to non-EU countries (implementing act). Best regards, [name removed] and [name removed] on behalf of the Norwegian Institute of Public Health (NIPH)
Boehringer Ingelheim · filed 10 Dec 2020 · source
Dear ladies and gentlemen, Boehringer Ingelheim welcomes the opportunity to provide feedback regarding the European Commission’s consultation regarding a draft implementing decision on Standard Contractual Clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council as set forth in the atteched document.
Norwegian Institute of Public Health · filed 9 Dec 2020 · source
Dear Commission, Please find attached our feedback on the draft Data protection - standard contractual clauses for transferring personal data to non-EU countries (implementing act). Best regards, [name removed] and [name removed] on behalf of the Norwegian Institute of Public Health (NIPH)
Boehringer Ingelheim · filed 9 Dec 2020 · source
Dear ladies and gentlemen, Boehringer Ingelheim welcomes the opportunity to provide feedback regarding the European Commission’s consultation regarding a draft implementing decision on Standard Contractual Clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council” set forth in the attached document.
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