15.7 Right to file a complaint

of a contract. As explained in Sections 11.1 and 11.2 of this report, the processing by government organisations and Google cannot be based on either of these legal grounds.

The individual right to data portability is independent of the situation where government organisations themselves would have to move their processing and files collectively to another provider. Google recognises this collective right to portability and has started the Data Transfer Project. Facebook, Microsoft, Apple and Twitter are participating in this initiative.285

15.7 Right to file a complaint

Finally, government organisations as (joint) controllers must inform their employees about their right to complain, internally to their Data Protection Officer (DPO), and externally, to the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).

In sum, neither Google, nor the government organisations are currently in a position to (fully) honour the rights of data subjects.

285 Data Transfer Project, URL: https://datatransferproject.dev/