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
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.
Viega Group · filed 7 Dec 2020 · source
On the Commission Implementation Decision: No feedback On the Annex: Section II, Clause 1, Module One, paragraph 1.7: The onwards transfer under sub-paragraph iii is not in line with the GDPR: Appropriate measures are concluded in Articles 45 to 50 and an agreement is not part of this.
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)
Viega Group · filed 26 Nov 2020 · source
On the Commission Implementation Decision: Article 3 should define how the evaluation of practical application is conducted. At least one method and a minimum sample size, if appropriate, should be defined. On the Annex: Clause 2 (a): States it is prohibited to modify the Clauses. However, options are to be chosen and clause 5 could be excluded what would be an modification. Options could be defined in an Annex.
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)
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