ZFODO's position on how to calculate the 72h deadline for reporting an incident to the regulator

5 February 2020

How should we expect 72 hours to report an incident?
Is this about getting the first information about the incident?
Do they start running for 72 hours only when, for example, the Data Protection Inspector finds an incident.

What does it mean to "state" an incident?
The key topic from the perspective of each person who, acting under time pressure, wondered if he would manage to report the incident within the Regulation deadline.