EDPB-EDPS Letter on European Commission draft proposal on simplification of record-keeping under the GDPR

"Based on the information available, and subject to a full analysis of the specific proposal, the EDPB and EDPS can express preliminary support to this targeted simplification initiative, bearing in mind that this would not affect the obligation of controllers and processors to comply with other GDPR obligations. Nevertheless, in order to better evaluate the impact of the proposed modification, the EDPB and EDPS consider it useful to understand, among other elements, the number of companies and organisations that would benefit from the simplification in the draft Proposal and its impact on the protection of personal data through an analysis carried out by the Commission." & "Given the importance of protecting data subjects under the GDPR, and of ensuring a balanced approach to the simplification, the EDPB and EDPS welcome that the obligation to keep records would in any event still be required for “likely high risk” processing."