Question about the Lead Supervisory Authority:
If the main establishment is in the UK and there are several establishments in Member States but without decision making power, does that mean that you can’t appoint a Lead Supervisory Supervisory Authority? Is that correct?
Also, if that is correct, what does that mean in practice? Can you get multiple fines for the same data breach for example? Since you can’t benefit from the one-stop-shop mechanism.
Dean
Hi there.
My understanding of the One-Stop-Shop in GDPR terms is that if an organisation does not have an entity in the EU that is making decisions, because all data processing decisions are determined by the UK entity, then that organisation can’t benefit from the O-S-S because there is no Main Establishment. In this case, the organisation might have to appoint an EU representative to be the focal point for data subjects and SA’s within the EU.