Article 62: Joint operations of supervisory authorities

Article 62 is operationally a “regulator coordination readiness” requirement: you must be able to respond quickly and consistently if EU supervisory authorities decide to run a joint investigation or enforcement action that involves staff from multiple Member States. Your job is to make cross-border inquiry intake, evidence production, and decision-making repeatable and auditable. (Regulation (EU) 2016/679, Article 62)

Key takeaways:

• Build a single intake-and-response path for all supervisory authority requests, including cross-border/joint operations triggers.
• Maintain a role-and-scope register so you can immediately map affected processing, systems, and legal entities.
• Prepare an “evidence packet” standard so responses are complete, consistent, and defensible under time pressure.

Article 62: joint operations of supervisory authorities requirement is directed at regulators, but it creates real operational expectations for controllers and processors that are subject to cross-border supervision. If multiple supervisory authorities coordinate a joint investigation or enforcement measure, you will be expected to engage through a clear point of contact, produce consistent records, and avoid contradictory statements across countries or entities. (Regulation (EU) 2016/679, Article 62)

For a Compliance Officer, CCO, or GRC lead, the fastest path to “operationalized” is to treat Article 62 as an extension of your regulatory inquiry management program: define who owns regulator communications, how you identify the processing in scope, how you preserve and produce evidence, and how you control messaging and remediation commitments across functions (Legal, Security, Privacy, Product, and regional leadership). If you do this work up front, you reduce delays, missed deadlines, and unnecessary friction during a multi-authority engagement.

This page gives requirement-level guidance you can put into practice: applicability, a step-by-step operating procedure, evidence to retain, exam questions you will get, and common mistakes that create avoidable exposure.

Requirement: Article 62 joint operations readiness (plain-English)

Plain-English interpretation. Article 62 says EU supervisory authorities may conduct joint operations, including joint investigations and joint enforcement measures, using members or staff from other Member States where appropriate. (Regulation (EU) 2016/679, Article 62) For you, that means: be ready for coordinated, cross-border supervisory activity that may involve multiple regulators asking aligned questions, requesting overlapping evidence, or coordinating onsite/remote investigative steps.

What “good” looks like in practice.

• One consistent front door for all regulator contact, triage, and response.
• A fast way to determine whether the matter is cross-border and which legal entities/systems are implicated.
• A controlled mechanism for evidence holds, collection, review, and production.
• A single narrative and decision log so different teams do not provide inconsistent answers.

Who it applies to (entity and operational context)

Entities. Any organization acting as a GDPR controller or processor for personal data in the EU/EEA that could be subject to supervisory authority inquiries, especially where processing spans Member States or involves multiple establishments. (Regulation (EU) 2016/679)

Operational contexts that raise the likelihood of joint operations.

• Multi-country operations (multiple EU establishments, shared services, centralized IT).
• Cross-border products (a single platform serving multiple Member States).
• Material incidents (security incident, large-scale complaint volumes, high-risk processing) that affect data subjects in more than one Member State.
• Complex third-party ecosystems (processors and sub-processors across geographies) where facts must be reconstructed from multiple sources.

Regulatory text

Text excerpt. “The supervisory authorities shall, where appropriate, conduct joint operations including joint investigations and joint enforcement measures in which members or staff of the supervisory authorities of other Member States are involved.” (Regulation (EU) 2016/679, Article 62)

Operator meaning. You do not “run” joint operations; the authorities do. Your obligation is indirect but concrete: make your organization capable of supporting a coordinated supervisory action without losing control of evidence, timelines, or accuracy. If you cannot quickly identify scope, preserve records, and respond consistently, you create avoidable regulatory risk.

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

Use this as an operating procedure your team can adopt as-is.

1) Establish ownership and a single regulator-contact channel

1. Name the accountable owner (typically Privacy/Legal with support from Compliance/GRC).
2. Centralize regulator communications (a designated email alias and case-management workflow).
3. Define intake rules: any employee receiving a supervisory authority request forwards it immediately; no one responds ad hoc.

Output: “Supervisory Authority Inquiry SOP” with roles (Accountable/Responsible/Consulted/Informed), escalation triggers, and approval points.

2) Maintain a GDPR role-and-scope register (your fast scoping tool)

Create and keep current a register that answers, for each major processing area:

• Controller vs. processor role
• Legal entity/establishment mapping
• Data categories and data subjects
• Systems and data stores involved
• Third parties involved (processors/sub-processors)
• Regional owners for Engineering/Security/Product

This is the difference between a controlled response and a scramble. It also reduces the risk factor where processing is performed without a clear role decision and scope determination. (Regulation (EU) 2016/679)

Output: Role-and-scope register tied to your RoPA and system inventory.

3) Add a “joint operation” triage decision to your inquiry workflow

When an inquiry arrives, triage for cross-border indicators:

• Are multiple Member States implicated?
• Does the inquiry mention coordination with another authority or staff from another Member State?
• Are multiple establishments or markets involved?

If “yes” or “unclear,” treat as potential joint operation. The operational change is tighter controls: single narrative, tighter evidence handling, and executive visibility.

Output: Triage checklist + documented triage decision per case.

4) Implement evidence preservation and an “evidence packet” standard

Joint operations create parallel questions from multiple angles. Standardize what you collect and how you present it.

Evidence packet template (minimum):

• Case summary and timeline (facts only; separate analysis)
• Scope statement (processing, systems, geographies, legal entities)
• Data flow diagram(s) for in-scope processing
• Policies/procedures relevant to the issue (privacy, security, incident, retention)
• Technical evidence (logs, configs, architecture diagrams) with source and chain-of-custody notes
• DPIA/LIA/consent or transparency materials if relevant
• Remediation plan and change log (what changed, who approved, when)

Operational control: legal hold / retention freeze process triggered by the inquiry, coordinated with IT/Security.

Output: Evidence packet per inquiry, stored with access controls and versioning.

5) Control statements and avoid inconsistent regulator messaging

Joint operations amplify inconsistencies. Put guardrails in place:

• Single draft owner for written responses.
• Review gates: Legal review; Privacy review; Security validation for technical claims.
• Meeting discipline: document attendees, questions asked, answers given, and follow-ups. If you do not know an answer, record that you will confirm and respond in writing.

Output: Regulator communications log + response approval record.

6) Align third parties quickly (processors, sub-processors, partners)

If facts live with third parties, you need a repeatable method to obtain evidence fast:

• Pre-defined contractual and operational contacts for urgent regulatory inquiries.
• A standard evidence request form (what you need, format, deadlines, confidentiality).
• A tracking mechanism for third-party responses and gaps.

This is where third-party risk management meets privacy operations: you are managing dependencies under regulator time pressure.

Output: Third-party inquiry playbook + contact registry.

7) Capture decisions, exceptions, and remediation as auditable records

You will be judged on consistency and follow-through as much as on the initial response.

• Record decisions (what you concluded and why).
• Record exceptions (what you could not produce and the reason).
• Track remediation commitments through closure.

Output: Auditable evidence packets on a recurring cadence (decision record, control outputs, exceptions, remediation). (Regulation (EU) 2016/679, Article 62)

Required evidence and artifacts to retain

Keep these in a dedicated “Supervisory Authority Inquiry” case file with access controls:

• Inquiry intake record (date received, channel, authority, request scope)
• Triage checklist and triage decision
• Role-and-scope register extract covering in-scope processing
• Data map / RoPA excerpts relevant to the inquiry
• Legal hold notice and confirmation of preservation actions
• Evidence packet and index of included files
• Communications log (emails, letters, meeting minutes)
• Response drafts with approvals (version history)
• Third-party outreach records and received evidence
• Remediation tracker and closure memo

Common exam/audit questions and hangups

Expect internal audit, external assurance, or regulator diligence to probe:

• “Show the end-to-end process for handling supervisory authority requests. Who owns it?”
• “How do you determine which EU establishment, product, and systems are in scope?”
• “How do you prevent inconsistent responses across regions and teams?”
• “How do you preserve evidence and ensure integrity of logs/config snapshots?”
• “How do you obtain evidence from processors/sub-processors quickly?”
• “Where is the decision record for what you told the authority, and who approved it?”

Hangups that slow teams down:

• No single inventory tying legal entities to systems and processing.
• Unclear controller/processor role for a product line.
• Logging gaps or short retention for key systems.
• Third-party contacts not defined for urgent regulatory requests.

Frequent implementation mistakes and how to avoid them

1. Mistake: Treating Article 62 as “not applicable because it’s about authorities.”
   Avoidance: Frame it as readiness for joint investigations. Your controls are inquiry intake, scope mapping, evidence handling, and governance. (Regulation (EU) 2016/679, Article 62)

2. Mistake: Letting local teams respond directly to their national authority.
   Avoidance: One communications owner, with local input. Centralize response drafting and approvals.

3. Mistake: Producing documents without an evidence index or version control.
   Avoidance: Use a standard evidence packet index; lock final versions; track what was produced and when.

4. Mistake: Over-promising remediation in early discussions.
   Avoidance: Separate facts from commitments. Route remediation promises through an approval gate with accountable owners.

5. Mistake: No third-party “rapid response” path.
   Avoidance: Pre-stage contacts and request templates. Test this as part of your incident/privacy exercises.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this page. Treat the risk as operational: joint operations increase the chance of conflicting narratives, missed deadlines, or incomplete evidence production, all of which can worsen outcomes in broader GDPR supervision. Article 62 also raises the bar for cross-border coordination inside your company because regulators may coordinate outside it. (Regulation (EU) 2016/679, Article 62)

Practical execution plan (30/60/90)

Note: Use these as phases (Immediate / Near-term / Ongoing). Adapt timing to your regulatory risk and footprint.

Immediate (stabilize the basics)

• Assign the accountable owner and backups for supervisory authority inquiries.
• Stand up the regulator intake channel and case log.
• Publish “no ad hoc responses” guidance to frontline teams (Support, Sales, Security, Privacy).
• Draft the evidence packet template and response approval workflow.

Near-term (make it repeatable)

• Build or refresh the GDPR role-and-scope register for major processing areas.
• Add the joint-operation triage checklist to your inquiry workflow.
• Define and test legal hold + evidence preservation runbooks with IT/Security.
• Create the third-party inquiry playbook (contacts, templates, tracking).

Ongoing (prove it works)

• Run tabletop exercises that simulate a cross-border inquiry with multiple stakeholders.
• Review closed inquiries for cycle-time delays, evidence gaps, and inconsistent statements.
• Keep the role-and-scope register current as systems and third parties change.
• Retain evidence packets in a structured repository for auditability.

Where Daydream fits (earned, not required)

If you want this to run like an operational program rather than a shared mailbox, Daydream can act as the system of record for inquiry intake, role-and-scope mapping, evidence packet checklists, approvals, and retention of the auditable record. That reduces the “policy exists but controls don’t operate” gap that shows up in supervisory scrutiny. (Regulation (EU) 2016/679, Article 62)

Frequently Asked Questions

Does Article 62 require my company to participate in joint investigations?

Article 62 describes what supervisory authorities do, but you should assume your organization may be asked to support coordinated inquiries and evidence requests across Member States. Operationalize it by making inquiry intake, scoping, and evidence production consistent and auditable. (Regulation (EU) 2016/679, Article 62)

What is the single most useful artifact to prepare ahead of time?

A GDPR role-and-scope register connected to your systems and processing inventory. It lets you identify affected legal entities, processing, and third parties quickly, which is where most teams lose time.

How do we prevent inconsistent answers across countries or business units?

Centralize drafting and approvals for all regulator communications, and require local teams to funnel facts through the case owner. Keep a communications log and a decision record so everyone works from the same source of truth.

We are primarily a processor. What changes?

You still need the same intake, scoping, and evidence discipline, but you must coordinate closely with your controller customers and align on what can be shared and who responds. Maintain third-party contact paths and contractual hooks to obtain and provide evidence quickly.

What should we do if a supervisory authority contacts an engineer or customer support directly?

Treat it as an exception event: route the request to the designated inquiry channel immediately and instruct the recipient not to respond substantively. Record the contact and preserve any relevant records tied to the request.

How do we test readiness without waiting for a real inquiry?

Run a tabletop exercise using a realistic cross-border scenario, then score performance against your checklist: intake speed, scoping accuracy, evidence packet completeness, approval controls, and third-party response handling.