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.
Industry association · Belgium
Declared costs: €50K+ a year · in the register since 2017
Industry association · Germany
Declared costs: €1M+ a year · in the register since 2008
Commission Implementing Decision on standard contractual clauses for the transfer of personal data to third countries · General Data Protection Regulation: additional procedural rules relating to the enforcement of the Regulation
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.
SCOPE Europe · filed 10 Dec 2020 · source
We appreciate the chance to provide comments on the new standard data protection clauses for the transfer of personal data to third countries pursuant to Article 46 GDPR. We acknowledge the great value of the updated framework, which will help companies when relying on third country transfers and hope our detailed comments may contribute to the further enhancement of the SDPC.
Bitkom e.V. · filed 10 Dec 2020 · source
We welcome the European Commission public consultation period on the Draft implementing decision and its Annex to discuss the standard contractual clauses (SCCs) for transferring personal data to non-EU countries as this is an important issue and an opportunity for stakeholders across all industries to provide input. Please find attached our detailed Position Paper.
SCOPE Europe · filed 24 Mar 2023 · source
Please, find the detailed joint-feedback as attachment. Following the key messages: 1. It is strongly recommended to extend the understanding of enforcement by integrating complementing tools, such as Codes of Conduct, into the evaluation by the European Commission. Codes of Conduct strongly support harmonization across Europe, by allowing for particularizing ambiguous interpretations in sector-specific manners.
Bitkom e.V. · filed 24 Mar 2023 · source
Bitkom is thankful for the opportunity to contribute to the consultation and welcomes future occasions to offer its expertise in open discussions. We welcome the ECs initiative intended to streamline cooperation between DPAs when enforcing the GDPR in cross-border cases, and to harmonize certain procedural aspects applied by DPAs in cross-border cases.
Bitkom e.V. · filed 4 Sept 2023 · source
Bitkom welcomes the proposal and its intention to streamline cooperation between DPAs when enforcing the GDPR in cross-border cases, and to harmonize certain procedural aspects applied by Data Protection Authorities (DPAs). We also view this process as an opportunity for a broader conversation on how to improve harmonization.
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