No, often data subjects will make a complaint to the Data Protection Commission (DPC) and another statutory body such as the Workplace Relations Commission, the Legal Service Regulatory Authority, the Ombudsman’s Office , and so on. However, those statutory bodies do not require the outcome of the DPC’s examination in order to make their own determination on the complaint that is before them. As with some cases before the courts, it may be necessary for the DPC to suspend or conclude its examination if that examination would interfere in the statutory functions of those bodies.

For more information, see our guidance on the supervision of personal data in the courts and certain statutory bodies exercising decision-making functions.

A data subject should also consider when submitting complaints to two bodies if the requests would directly interfere with each other. For example, if a data subject makes an erasure request to a data controller but also makes a complaint to the Workplace Relations Commission (WRC) to examine an employment dispute. It would be very difficult for the data controller to comply with the erasure request from either the data subject or in response to an examination by the DPC, and provide a strong defence in the WRC proceedings. It is also not efficient for the resources of both bodies to be tied up examining two conflicting complaints like this. The data subject must choose their priority and pursue that to its conclusion before deciding on the next course of action, if any.