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Article 27 GDPR

→  Individual  Requests and Cooperation

Who needs an EU representative ?

Non-EU company processing data concerning EU residents and EU citizens worldwide, have an obligation to appoint an EU Representative if the Processor or Controller is a company established in the EU.

There should be at least 1 EU Rep. for the whole EU. 

Such company that does not appoint an EU Representative is in breach of its obligations under GDPR.

Will the EU Rep pay my fines ?

No, because a fine would be against a company outside the EU and would require an international procedure. Eu Reps are not DPOs and cannot certify  the remote company. DPO(s) of your EU contractors cannot be EU Reps due to conflicts of interests. As a consequence, it is not the EU Representative who guarantees your process but your contractor through inexecution clauses. Pure-Rep is here to make sure the contract is executed. Pure-Rep can also work with your lawyers to draft the contract. Read more (official  EU content) 

Permanent or temporary Representation ?

The EU Rep is required as long as the process is executed. It can be in the context of a three-month contract, up to 10 years, or as long as an application is in use.

Clients could also choose to appoint several EU Reps in various EU States, all of them working as a network or independantly. One of Pure-Rep own external resource besides lawyers and translators, is actually other EU Reps in other EU States, making it easier to scale our own scope of intervention for each client.

What will Pure-Rep do exactly ?

When the processor is in the EU, Pure-Rep function is about monitoring the rights of the EU data subjects involved in one or more singular process(es). Pure-Rep will check that individual requests are enforced either by on-site visits or by online communication, and reports to the Non-EU Company. 

The EU Representative is also the voice of the non-EU company in the EU. Pure-Rep does English/French “by design” at no extra cost, and other languages can be added when required. Paris is an international city and remote resources are widely available. Pure-Rep can process subjects speaking any EU language with the appropriate budget.

Is it not about the GDPR sanctions ?

Appointing an EU Representative means that a process will be notified to the supervisory authority  who will be able to review it. Occasionally an Authority may  comment, advise or alert the client that a process could be improved to offer better guarantees.  However, it is often after a incident has occurred that the Data Authorities will dive into your documents for a first check of the process impact. Appointing an EU Representative  is about installing a cooperation with the Data Authorities, and does not change anything to your procedural rights.

Clinical trials & EU Legal  Representation ?

Pure-Rep is not a “EU Legal Representative” of Art. 19 of the EU directive 2001/20/EC dealing with clinical trials and common/criminal liability of the “Sponsor”. GDPR does not involve any criminal or civil liability.  Pure-Rep is a “Pure” EU Representative of Art. 27 GDPR with functions limited to article 27 GDPR.

Get in touch

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Geographical advantage ? 

PureRep is currently located in Paris, France (France > 65 millions residents). Services like translation firms and  sworn translators, international CRM software, legal counsels, are numerous and of high quality due to high international exposure. Of course, international online resources are also available. Did you know that you can plead cases in English in Paris ?