C037-208 Twitter International Company, Twitter, Inc.

Pointing out to the DPC that they should investigate in full and take into account the legal provisions mentioned in the complaints.

Letter to DPC for Clarification

DPC has commenced an Inquiry under Section 110 1 of the Act 18

Submission by noyb sent violation type K outstanding

noyb replied that the complaint outlines the categories of personal data that Twitter has collected as a result of the setting of the cookies and that violation type K has not been remedied yet.

DPC replied they will forward noyb's response to Twitter and ask Twitter if they are able to proceed to reply to the DPC in the absence of this information.

DPC forwarded to us a response from Twitter. Twitter claims that it was unable to confirm the requested information.

noyb responded to the DPC that they excluded one case from their list of complaints and requested that all complaints be covered.

DPC confirmed they will start the investigation of 17 complaints.

DPC one-liner they will respond in the coming days

noyb responded that the DPC is competent to investigate the cases under the GDPR and that it does not make sense to forward them to the telecoms authorities abroad. noyb provided evidence that personal data was processed when submitting complaints.

DPC letter insisting they are not competent to investigate

DPC worte that they will respond in the coming days.

noyb responded that that (1) this does not make sense under Irish ePrivacy law and (2) the complaint is brought also under GDPR and their own ePrivacy guidance says that if there is personal data in a cookie, GDPR applies.

DPC wrote that their assessment suggests that the DPC may not be the competent authority to carry out investigations under Regulation 17 of S.I. No. 336 of 2011 because the complainant's device was outside of Ireland at the time of the violation.

DPC is still into it and the appropriate legislative framework under which to deal with them.

noyb asked DPC to indicate a specific date when the next update can be expected and when we can get access to the submissions, if any were made.

DPC acknowledged receipt of the complaint and is assessing it.