Article 67: Exchange of information

Article 67 is not a direct controller/processor action item; it authorizes the European Commission to set the electronic information-exchange arrangements between supervisory authorities and the EDPB. Your job is to operationalize readiness: run regulator interactions through a controlled, secure, traceable workflow so you can respond in the formats and channels supervisory authorities require. (Regulation (EU) 2016/679, Article 67)

Key takeaways:

• Treat Article 67 as an “interface requirement”: build a disciplined regulator-communications process that can adapt to standardized electronic formats.
• Centralize ownership, intake, approvals, and evidence for any supervisory authority correspondence that involves personal data or case files.
• Keep auditable records of what you sent, to whom, when, under what legal basis, and with what security controls.

Article 67: exchange of information requirement sits in the GDPR’s cooperation and consistency machinery. The text is short, but it signals something operational teams regularly miss: supervisory authorities are expected to exchange information electronically with each other and with the Board, and the Commission can standardize how that happens, including standardized formats referenced in Article 64. (Regulation (EU) 2016/679, Article 67)

For you as a Compliance Officer, CCO, or GRC lead, the practical implication is not that you must build EU regulator-to-regulator integrations. It’s that regulator interactions affecting your organization will increasingly arrive as structured, electronic requests, and your responses may need to fit defined formats and secure channels. If your response handling is ad hoc (email chains, unclear owners, unlogged submissions), you create avoidable risk: missed deadlines, inconsistent statements, uncontrolled disclosures, and weak defensibility in later inquiries.

This page translates Article 67 into an operational readiness control set: a regulator communications procedure, scoped ownership, secure transfer methods, decision records, and an evidence packet discipline. The goal is simple: you can receive, triage, respond, and prove what happened, even if the exchange method evolves. (Regulation (EU) 2016/679, Article 67)

Regulatory text

Regulatory excerpt: “The Commission may adopt implementing acts of general scope in order to specify the arrangements for the exchange of information by electronic means between supervisory authorities, and between supervisory authorities and the Board, in particular the standardised format referred to in Article 64.” (Regulation (EU) 2016/679, Article 67)

What the operator must do with this

Article 67 gives the Commission authority to standardize how supervisory authorities and the EDPB exchange information electronically. You do not implement those exchanges yourself, but you should assume that:

• regulator communications affecting you can be routed and processed electronically,
• authorities may expect structured submissions,
• and you will be assessed on whether your responses are secure, consistent, and evidence-backed. (Regulation (EU) 2016/679, Article 67)

Operationally, treat this as a “be ready for standardized electronic regulator workflows” requirement. Your implementation should focus on: (1) controlled intake and routing of supervisory authority communications, (2) secure preparation and transmission of response materials, and (3) retention of a complete evidence trail.

Plain-English interpretation

• What Article 67 says: the Commission can specify the electronic arrangements and formats used for information exchange among EU data protection regulators and the EDPB. (Regulation (EU) 2016/679, Article 67)
• What it means for you: you need a repeatable way to handle regulator communications that can accommodate electronic, standardized submissions without scrambling, improvising, or losing records.

This is a maturity test more than a “checkbox.” During regulatory engagement, the fastest way to damage credibility is inconsistent messaging or an inability to reconstruct what was provided.

Who it applies to

Entity scope

• Controllers and processors subject to the GDPR who may interact with supervisory authorities (directly or via counsel), especially during complaints, investigations, breach notifications, cross-border processing matters, or cooperation procedures. (Regulation (EU) 2016/679)

Operational context (where this shows up)

• Any event where a supervisory authority requests information, documents, logs, DPIAs, policies, contracts, or technical evidence.
• Any scenario where you provide a written submission that includes personal data, case details, or internal investigative findings that relate to data subjects.

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

Below is a practical build that turns Article 67 readiness into a control you can run.

Step 1: Define scope and roles (controller vs. processor) for regulator interactions

Create a role-and-scope register for supervisory authority communications:

• Your role for the processing at issue (controller/processor; joint controller if applicable).
• Categories of personal data that could appear in submissions (customer, employee, prospects, sensitive categories if relevant).
• Systems likely to be pulled for evidence (ticketing, IAM, DLP, logging, HRIS, CRM, data lake).
• Named accountable owners (Legal, Privacy, Security, Product, Ops). (Regulation (EU) 2016/679)

Why this matters: response obligations and permissible disclosures depend on your role and the context of the request. When teams skip role clarity, they over-disclose or under-produce.

Step 2: Stand up a regulator request intake and triage workflow (single front door)

Implement a “single front door” for supervisory authority communications:

• A central mailbox or case management queue owned by Privacy/Legal with backup owners.
• A standard intake form capturing: authority name, request type, scope, deadlines, requested formats/channels, and whether personal data is implicated.
• A triage rubric: routine inquiry vs. formal investigative demand; cross-border signal; urgency; data sensitivity; need for outside counsel. (Regulation (EU) 2016/679)

In practice, this prevents parallel, conflicting responses from different departments.

Step 3: Establish secure electronic exchange methods and guardrails

Because Article 67 focuses on electronic exchange arrangements, define your acceptable response channels and protections:

• Approved transmission methods (secure portal, encrypted email, secure file transfer) and who can authorize exceptions.
• A checklist for redaction, minimization, and attachment review before sending.
• Access control and least-privilege for staff preparing submissions. (Regulation (EU) 2016/679, Article 67)

Keep it pragmatic: you are not predicting the Commission’s implementing acts; you are ensuring you can comply with whatever structured electronic expectations arrive.

Step 4: Standardize your response package structure (template-driven)

Build templates for common regulator response artifacts:

• Response letter structure: request reference, scope confirmation, summary of searches performed, findings, and attachments index.
• Evidence index template: file name, source system, date range, collection method, hash/signing approach if used, redaction status.
• “Decision record” template: what you disclosed, legal basis, why you limited scope, who approved. (Regulation (EU) 2016/679)

This is where “standardized format” becomes real operationally: even if the authority’s format changes, your internal production becomes consistent and fast.

Step 5: Add approvals and representation controls

Define explicit approvals for:

• Any statement about facts (Security validates incident timelines; Product validates system behaviors).
• Any statement about legal interpretations (Legal/Privacy).
• Any disclosure of personal data or internal logs (Privacy + Security sign-off). (Regulation (EU) 2016/679)

Avoid “reply-all compliance.” Treat submissions as regulated outputs.

Step 6: Retain an auditable evidence packet for every exchange

For each supervisory authority interaction, retain a complete evidence packet:

• Intake record and classification.
• Copy of all inbound requests (including envelopes/headers where relevant).
• All drafts and final submitted materials.
• Attachment list and the final versions sent.
• Proof of transmission/receipt (portal receipt, sent email headers, courier proof if applicable).
• The approval chain and decision record.
• Exceptions and remediation actions if errors occurred. (Regulation (EU) 2016/679, Article 67)

This evidence packet is what you need when questions arise months later.

Required evidence and artifacts to retain

Use this checklist as your minimum defensibility set:

Artifact	What it proves	Owner
Role-and-scope register for regulator interactions	You identified applicable roles, data categories, and systems	Privacy/GRC
Regulator intake log / case record	Central control over requests and deadlines	Privacy Ops / Legal Ops
Response templates and current SOP	Repeatable process tied to owners and approvals	GRC + Legal/Privacy
Approval records (who approved what, when)	Statements and disclosures were governed	Legal/Privacy
Transmission proof and final submission package	What you actually sent and through what channel	Privacy Ops
Exception records and corrective actions	You detect and fix process breakdowns	GRC

These artifacts align directly with the “documented in policy vs. operating in reality” gap regulators tend to probe. (Regulation (EU) 2016/679, Article 67)

Common exam/audit questions and hangups

Expect internal audit, external assurance teams, and customer diligence reviewers to ask:

• “Show me your workflow for supervisory authority requests, including owners and backups.”
• “How do you prevent inconsistent statements from different functions?”
• “What are your approved channels for transmitting personal data to regulators?”
• “How do you validate completeness and accuracy of submissions?”
• “Can you reproduce exactly what you sent for a prior inquiry, including attachments and timestamps?” (Regulation (EU) 2016/679, Article 67)

Common hangup: teams can produce the final letter but not the decision record, approvals, or proof of what attachments were included.

Frequent implementation mistakes and how to avoid them

1. No single owner for regulator communications.
   Fix: assign a primary accountable owner in Privacy/Legal and document backups in the SOP.

2. Treating regulator responses like normal email.
   Fix: require controlled drafting, approvals, and secure transmission methods for any case that includes personal data or investigative details. (Regulation (EU) 2016/679, Article 67)

3. Inability to reconstruct the record.
   Fix: evidence packets are non-negotiable. Store them in a controlled repository with access logging and retention rules.

4. Unclear role (controller vs. processor) during responses.
   Fix: keep the role-and-scope register current and link each request to the relevant processing context. (Regulation (EU) 2016/679)

Enforcement context and risk implications

No public enforcement cases were provided for Article 67 in the source catalog, so this page does not cite specific cases.

Risk still shows up in predictable ways:

• Operational risk: missed or inconsistent responses escalate regulator scrutiny and extend investigations.
• Confidentiality risk: uncontrolled sharing of logs, screenshots, or datasets can disclose more personal data than necessary.
• Governance risk: poor recordkeeping weakens your ability to defend decisions, especially when multiple supervisory authorities are involved. (Regulation (EU) 2016/679, Article 67)

A practical execution plan (phased, no calendar math)

Use phases rather than fixed day counts so you can move quickly without inventing timing.

Immediate phase (set the foundation)

• Name a single “front door” owner and backups for supervisory authority communications.
• Stand up the intake log and case record template.
• Draft the regulator-communications SOP with trigger events and approvals.
• Define approved transmission channels and exception approvals. (Regulation (EU) 2016/679, Article 67)

Near-term phase (make it repeatable)

• Build response templates (letter, evidence index, decision record).
• Implement an evidence packet repository with controlled access.
• Run a tabletop: simulate an authority request that requires logs, contracts, and a narrative response, and test approvals end-to-end. (Regulation (EU) 2016/679)

Ongoing phase (operate and improve)

• Review completed cases for defects: missed artifacts, unclear approvals, over-broad disclosures.
• Update the role-and-scope register as systems and processing change.
• Keep the SOP current so it can adapt if standardized electronic formats become more prescriptive. (Regulation (EU) 2016/679, Article 67)

Tooling note (where Daydream fits)

If you are already tracking controls and evidence in Daydream, map Article 67 to a lightweight “regulator exchange readiness” control set: scope register, SOP, and recurring evidence packets. Daydream’s value here is traceability: one place to show ownership, operating cadence, exceptions, and the evidence bundle without hunting through email and shared drives.

Frequently Asked Questions

Does Article 67 require my company to implement a specific electronic system to exchange information with regulators?

No. Article 67 authorizes the Commission to specify arrangements for exchanges between supervisory authorities and the EDPB. Your practical obligation is readiness: controlled intake, secure response handling, and evidence retention that can adapt to electronic and standardized submission expectations. (Regulation (EU) 2016/679, Article 67)

What should I do if a supervisory authority requests a “standard format” submission?

Use your response templates and evidence index to normalize your production, then align the final packaging to the authority’s stated format and channel. Record the format requirement in the case file and retain proof of the exact files transmitted. (Regulation (EU) 2016/679, Article 67)

We’re a processor. Should we respond directly to regulators?

Sometimes regulators contact processors, but your contract and the context matter. Route all requests through the single front door, coordinate with the controller where appropriate, and document your role decision and approvals in the decision record. (Regulation (EU) 2016/679)

What evidence is most valuable in an audit of this area?

Auditors usually want to see the intake log, the SOP with named owners, and complete evidence packets that recreate a past exchange end-to-end (request, approvals, submission, proof of sending). Those items demonstrate operational control rather than policy-only compliance. (Regulation (EU) 2016/679, Article 67)

Can we store regulator correspondence in email if we keep it organized?

Email alone is fragile for defensibility because attachments, approvals, and final versions get fragmented. If you must start in email, export a complete evidence packet to a controlled repository with access controls and a clear index of what was sent. (Regulation (EU) 2016/679, Article 67)

How do we prevent over-disclosure when sending logs or datasets to an authority?

Require Privacy and Security review before sending, apply minimization and redaction where appropriate, and document the disclosure rationale in a decision record. Your SOP should force a deliberate choice, not an “attach everything” response. (Regulation (EU) 2016/679)