Submission of a prior consultation request to the HDPA

To submit a prior consultation request to the HDPA, the controller must fill in a special form and submit it electronically* through the HDPA online portal. This form includes a section on whether it has been verified that the prior consultation request meets the necessary formal conditions to be considered by the HDPA.

(*) Only in exceptional cases can the form be submitted differently (e.g. in person), while the reason for not using electronic submission should be adequately documented.

The electronic submission mentioned above consists, in short, in the following steps:

  1. The controller must log in to the HDPA online portal under the option “Body”, using the credentials he/she has for taxisnet.
  2. Fill in the fields of the electronic form provided by selecting the option “Prior consultation request”.
    To verify that the necessary formal criteria for completeness of the prior consultation request are met, fill in questions 1-3 in this form.
  3. Attach one or more separate files to the above electronic form (preferably in word format) in connection with the following:
    1. a description of the prior consultation request,
    2. the document of the relevant DPIA provided for in Article 35 GDPR,
    3. a description of all the information documenting the answers given in questions 1-3 in the electronic form, and
    4. any other evidence/documents directly related that are considered necessary for documenting the prior consultation request.

Exceptionally submit a prior consultation request to the HDPA by e-mail

In case that, for any documented reason, you cannot log in to the HDPA online portal, you can submit a prior consultation request by e-mail. Please note, however, that you can only use this way as an exception, i.e. an alternative to submitting the relevant request to the HDPA.

In this case, follow the steps outlined below:

  1. Fill in all required fields in the form below (at the end of this form you can find relevant instructions for completion):

Request form (docx / pdf) for prior consultation of the HDPA with regard to the DPIA.

 

  1. Send an e-mail to the prior_consultation@dpa.gr mailbox attaching the following:
    1. The above form filled in.
      The grounds for submitting a prior consultation request to the HDPA can only be documented if all the criteria for completeness specified in section 5 of the above form are met.
    2. One or more separate files (preferably in word format) containing details of describing and documenting the prior consultation request, as specified in section 6 of the above form.
    3. An outline of the reasons that have led you to submit the prior consultation request in this way rather than through the HDPA online portal.

For security reasons, we suggest that you send the form encrypted in such a way that it can be read (decrypted) only by the HDPA.

To achieve that, you should use the GnuPG (GPG) software, which is a free distribution of the OpenPGP standard.

You must first encrypt the file (i.e. the filled in form) on the controller’s computer, regardless of the software/e-mail service you use and then attach the encrypted file to an e-mail message.

The above step should be repeated for the attached DPIA document and/or for other documents/texts/files attached by the controller.

The HDPA’s public GPG key, which must be used to encrypt the completed form before attaching it to the e-mail message* to be sent to the HDPA, is available here (Key ID: 69B7D6BC, Key Fingerprint: 67D7 EAB0 26E6 73AB 10EA C09F 614D 0796 69B7 D6BC). The DPIA document as well as any file accompanying the form may be encrypted in the same way.

*Warning: Please do not encrypt the whole e-mail message (e.g. by using an appropriate plugin), because there are known security issues in this approach (see here).