Abstract

One of the major challenges faced by data controllers in connection with the General Data Protection Regulation is the implementation of procedures and technical solutions enabling exercise of the right of natural persons to transfer their personal data. The right to personal data transfer is a part of a broader concept of data transferability in the information society and Digital Single Market. Of importance is its pro-consumer and pro-competition dimension. The exercise of this right involves several additional duties of data controllers and failure to satisfy them is penalized with high administrative fines. At the same time, the benefits for data subjects are quite limited. At present, there is no legal certainty with respect to Article 20 which makes its ultimate interpretation hardly feasible.