1. What is the ODP’s position if a Data Controller does not meet certain regulatory requirements or experiences a delay in responding to Data Subject rights requests during the current COVID-19 situation?

Data Controllers should always seek to comply with their obligations under the DP Regulations. However, during these uncertain times, the ODP understands that Data Controllers might be distracted and there may be delays in responding to Data Subject requests and other compliance requirements under the DP Regulations. The ODP will take a pragmatic approach to regulation during these uncertain times and will take into consideration any mitigating circumstances before deciding what regulatory action to take (if any) against Data Controllers for non-compliance.