Article 57: Tasks

Compliance teams rarely read Article 57 because it assigns tasks to supervisory authorities, not to organizations. In practice, it still matters to you because Article 57 describes what DPAs are mandated to do on their territory, and those tasks drive what they will ask you for and how quickly they will expect you to respond. If you cannot handle a complaint intake, an information request, or a cooperation touchpoint cleanly, you create avoidable legal exposure and operational churn.

This page focuses on the “article 57: tasks requirement” as an operational readiness requirement: you need a defined way to engage with your lead DPA and any other relevant supervisory authority, produce consistent answers, and prove what you did. That means tight ownership, scoped records of processing, and defensible evidence retention. The goal is not to predict enforcement; it is to remove chaos when a regulator inquiry lands and your business needs you to respond with confidence. (Regulation (EU) 2016/679, Article 57)

Regulatory text

Excerpt (provided): “Without prejudice to other tasks set out under this Regulation, each supervisory authority shall on its territory:” (Regulation (EU) 2016/679, Article 57)

Operator interpretation: Article 57 is addressed to DPAs, but it tells you what DPAs are expected to do (for example, handle complaints, monitor and enforce the GDPR, raise awareness, cooperate with other authorities). You cannot “comply” with Article 57 directly; you operationalize it by ensuring your GDPR program can support DPA tasks without delay or inconsistency.

What you must be able to do, operationally (minimum bar):

• Receive and triage any contact linked to DPA tasks (complaints, inquiries, investigation notices).
• Respond consistently with accurate scope, role, and processing facts.
• Prove your actions through an auditable evidence trail.

This requirement-level page focuses on the controls that make those outcomes repeatable. (Regulation (EU) 2016/679, Article 57)

Plain-English interpretation (what the requirement means for you)

DPAs have a statutory job to supervise GDPR in their territory. If you operate there, you should assume the DPA can contact you, ask for information, expect cooperation, and evaluate whether your actions match your documentation. Your job is to be “regulator-ready”:

• You know who owns the regulator relationship.
• You can quickly map a question to processing activities, systems, and third parties.
• You can produce records, decisions, and remediation proof without rebuilding the story from scratch.

Who it applies to

Entity types: Any organization processing personal data that falls under GDPR scope, whether acting as a controller or processor, because DPA actions (complaints handling, inquiries, investigations) frequently involve both. (Regulation (EU) 2016/679)

Operational contexts where this becomes urgent:

• You receive a complaint forwarded by a DPA or a notice of inquiry.
• Your customer (as controller) pulls you in as a processor/sub-processor for an ongoing DPA matter.
• You expand into new EU/EEA markets and need a clear lead DPA engagement model.
• You have high-risk processing (large-scale, sensitive data, tracking/ads tech, employee monitoring) and expect scrutiny.

What you actually need to do (step-by-step)

1) Assign a single “DPA interface” owner and backups

• Name an accountable owner (usually Privacy/Legal/CCO office) with authority to coordinate facts across Security, Engineering, Product, HR, and Support.
• Define backups and escalation paths for time-sensitive matters.
• Document who can approve external communications to a DPA and who signs submissions.

Why auditors care: When ownership is unclear, responses become inconsistent across teams, and DPAs see gaps between statements and operational reality.

2) Create a role-and-scope register tied to Article 57 readiness

Maintain a living register that answers, for each major processing activity:

• Are you controller, processor, or joint controller?
• What categories of personal data and data subjects are involved?
• What systems process the data?
• What third parties receive or process the data?
• What cross-border elements exist?

This aligns directly with the recommended control: “Maintain a GDPR role-and-scope register… including controller/processor role, data categories, and affected systems.” (Regulation (EU) 2016/679, Article 57)

Practical tip: Build it so you can answer regulator questions without re-interviewing every system owner.

3) Define a requirement-specific operating procedure (SOP) for DPA matters

Write a short SOP that covers:

• Trigger events: Any letter/email from a DPA, any complaint reference number, any request from a customer related to a DPA.
• Intake channels: Privacy inbox, ticketing system, legal portal, customer support escalation.
• Triage rules: What qualifies as potential investigation vs. informational request; when to involve outside counsel.
• Fact-finding checklist: Pull records of processing, DPIA/legitimate interest assessment if relevant, security incident history, data flow diagram, vendor chain.
• Response workflow: Draft, review, approvals, submission, and follow-ups.
• Retention: Where the evidence packet is stored and who can access it.

This aligns with: “Define a requirement-specific operating procedure with named owners, trigger events, and required approvals.” (Regulation (EU) 2016/679, Article 57)

4) Build an “evidence packet” standard for every regulator interaction

For each DPA matter, retain a folder/package containing:

• Intake record (email/letter, date received, who received it)
• Triage decision record (severity, scope, legal theory, affected processing)
• Internal fact set (system notes, logs pulled, data maps referenced)
• Drafts and approvals (who approved what, when)
• Submission copy (exact response sent)
• Remediation actions and verification (tickets, change records, policy updates)
• Closure note (final outcome, lessons learned)

This aligns with: “Retain auditable evidence packets (decision record, control outputs, exceptions, and remediation) on a recurring cadence.” (Regulation (EU) 2016/679, Article 57)

5) Operationalize cooperation across functions (no heroics)

You need pre-committed participation from:

• Security: incident timelines, controls, access logs, risk acceptance records
• Engineering/Product: data flows, feature behavior, deletion mechanics
• Support/Trust: user communications history, complaint artifacts
• Procurement/TPRM: third-party contracts, sub-processor list, due diligence outputs

Make this a standing RACI and include it in onboarding for system owners.

6) Run a tabletop: “DPA inquiry arrives tomorrow”

Test your process with a scenario:

• A DPA requests information about a specific processing activity and third-party sharing.
• Validate that you can produce: role decision, data categories, system list, third parties, and the exact internal approver chain.
• Capture gaps as remediation items with owners and due dates.

Required evidence and artifacts to retain

Use this as an audit checklist:

Artifact	What “good” looks like	Owner
DPA Interface SOP	Trigger-based, named approvers, escalation defined	Privacy/CCO
Role-and-scope register	Controller/processor role + systems + data categories + third parties	Privacy + GRC
DPA interaction log	All inbound/outbound tracked with timestamps and status	Privacy Ops
Evidence packets	Complete decision trail per matter, stored centrally	Privacy/Legal
Cross-functional RACI	Security/Product/Support participation commitments	CCO/GRC
Remediation tracker	Corrective actions tied to DPA matters, verified closed	GRC

Common exam/audit questions and hangups

• “Show me your process for handling regulator inquiries.” Auditors will look for an SOP and evidence it is used (tickets, logs, approvals).
• “Who can speak for the company to a DPA?” If multiple teams reply ad hoc, expect findings about governance and inconsistent statements.
• “How do you know your controller/processor role for this processing?” Missing role decisions cause contradictory responses.
• “Prove the facts you asserted.” DPAs and auditors care about evidence, not narratives.

Hangup that burns time: teams store evidence in personal mailboxes or chat threads. Centralize it.

Frequent implementation mistakes (and how to avoid them)

1. Treating Article 57 as “not applicable.”
   Avoidance: mark it as “DPA readiness” in your control library and map it to your regulator-response process. (Regulation (EU) 2016/679, Article 57)

2. Policy-only compliance.
   Avoidance: require an evidence packet for every inquiry, even small ones. That creates operating proof.

3. Unclear role decisions (controller vs processor).
   Avoidance: maintain and review the role-and-scope register during product launches and major customer deals.

4. No third-party chain visibility.
   Avoidance: tie sub-processor lists and key third-party risk records to the processing activity so you can answer “who else touches the data?” quickly.

Enforcement context and risk implications

No public enforcement cases were provided in your source catalog for this page, so this section stays practical rather than case-driven. The operational risk is still clear: DPAs are tasked to supervise and enforce GDPR on their territory, and organizations that cannot respond coherently increase the chance of adverse outcomes, extended investigations, and reputational damage. (Regulation (EU) 2016/679, Article 57)

Practical 30/60/90-day execution plan

Use phased execution without assuming fixed effort or headcount.

First 30 days (Immediate foundation)

• Appoint DPA interface owner, backups, and approver chain.
• Stand up a single intake channel and tracking log for regulator contacts.
• Draft the DPA Interface SOP (one version-controlled document).
• Define the evidence packet template and storage location.

Next 60 days (Operationalization)

• Build the role-and-scope register for your highest-risk processing areas first.
• Align the RACI across Security, Product, Support, and Procurement/TPRM.
• Run one tabletop exercise and record corrective actions in your GRC tracker.

Next 90 days (Prove operation and harden)

• Complete role-and-scope coverage for remaining processing activities in scope.
• Start recurring evidence reviews (spot-check packets for completeness and approvals).
• Add “regulator inquiry readiness” to onboarding for system owners and to incident response coordination.

Where Daydream fits: Daydream can act as the system of record for the SOP, role-and-scope register, and evidence packets, so your regulator-response story is consistent across privacy, security, and third-party risk workflows.

Frequently Asked Questions

Does Article 57 impose direct obligations on my company?

Article 57 sets out tasks for supervisory authorities, not a direct “thou shalt” list for controllers and processors. Operationally, you should prepare to support those tasks through a regulator-ready intake, response, and evidence process. (Regulation (EU) 2016/679, Article 57)

What’s the single most important artifact to build first?

Create the DPA Interface SOP and an evidence packet template, then enforce them for every inquiry. That converts ad hoc responses into repeatable operations.

How do we handle DPA requests when we are only a processor?

Route the inquiry through your DPA interface owner and coordinate with the customer (controller) under your contract and instructions. Keep your own evidence packet so you can prove what you received, what you provided, and what you escalated.

Do we need a separate process from data subject request (DSAR) handling?

Keep them distinct but connected. DSAR ops handles individual rights requests; the DPA interface process handles regulator communications, escalations, and investigations, which often reference DSAR history.

What evidence do auditors expect beyond the final response letter?

They expect the decision trail: intake, triage rationale, who verified facts, who approved the response, and what remediation you executed. Store it as a single packet per matter.

How do we prevent inconsistent statements across Legal, Security, and Support?

Use one tracking system, one owner, and a documented approval chain. Require that all external statements to DPAs reference the same internal fact set and are stored in the evidence packet.