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.
Company · Germany
Industry association · Belgium
Declared costs: €3.5M+ a year · in the register since 2011
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.
DIGITALEUROPE · filed 10 Dec 2020 · source
DIGITALEUROPE welcomes the new set of standard contractual clauses (SCCs) for transferring personal data to third countries published by the European Commission. In particular, the new modular approach allows for many processing and transfer situations that were not captured under the current SCCs, bringing greater clarity and protection along with further modifications necessary in light of the General Data…
DIGITALEUROPE · filed 10 Dec 2020 · source
DIGITALEUROPE welcomes the new set of standard contractual clauses (SCCs) for transferring personal data to third countries published by the European Commission. In particular, the new modular approach allows for many processing and transfer situations that were not captured under the current SCCs, bringing greater clarity and protection along with further modifications necessary in light of the General Data…
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.
DIGITALEUROPE · filed 10 Dec 2020 · source
DIGITALEUROPE appreciates the opportunity to contribute its input to the new set of standard contractual clauses (SCCs) between controllers and processors located in the EU published by the European Commission. Contract negotiations following the General Data Protection Regulation (GDPR) have centrally revolved around defining clear tasks of the parties, as separate or joint controllers or processors; as in any…
DIGITALEUROPE · filed 10 Dec 2020 · source
DIGITALEUROPE appreciates the opportunity to contribute its input new set of standard contractual clauses (SCCs) between controllers and processors located in the EU published by the European Commission. Contract negotiations following the General Data Protection Regulation (GDPR) have centrally revolved around defining clear tasks of the parties, as separate or joint controllers or processors; as in any other…
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