24 October 2019

Following the publication of the European Commission’s communication ‘Data protection rules as a trust-enabler in the EU and beyond – taking stock’ of July 2019 and in view of the evaluation and review of the Regulation due to be carried out by May 2020, Intergraf submitted its experience and views on the application of the General Data Protection Regulation (GDPR) to the European Commission in the attached position paper.

The GDPR regulation of the European Union is highly complex and a burden for many companies in the printing industry. The administrative procedures are particularly difficult for small and medium sized enterprises which constitute 90% of the printing industry. Printing companies work with data that is generally not sensitive and does not pose a risk to the rights and freedoms of natural persons.

Intergraf, as the representative of the European printing industry, calls on the European Commission to support a pragmatic implementation of the Regulation in particular for small and medium sized enterprises (SMEs).

The duty of information and the record keeping of processing activities generate a burdensome administrative work for SMEs. These requirements should focus more on high-risk data processing.

Intergraf also supports a pragmatic implementation of the Regulation for companies. When interpreted too strictly, the right to erasure or right of access to personal data may be impossible to implement in practice and may also generate abusive requests in case of disputes with customers or employees.

According to Article 97 of the GDPR, the European Commission is due to submit a report on the evaluation and review of the Regulation to the European Parliament and the Council by 25 May 2020. For more information please read the summary position paper, here.

– ENDS –

Notes to Editor

Intergraf is the European federation for print and digital communication. We are a Brussels-based trade association representing employers in the European printing industry. Intergraf represents 21 national printing federations in 20 countries. Our primary task is to represent and advocate for the interests of the printing and digital communication industry in Europe, working with European Union to support the sector’s competitiveness through advocacy, information-sharing, networking and social dialogue. For more information, please visit:

For more information please contact:

Alison Grace
Communications & Policy Officer at Intergraf
Email: This email address is being protected from spambots. You need JavaScript enabled to view it.
Tel: +32 (0) 2 230 86 46