GDPRhub commentary style guide

This page provides specific guidance on the Commentary. For general information regarding the writing style on the Hub, including on the Commentary, please follow this guide.

General Information for Commentary Articles

The GDPRhub Commentary features relatively short analysis regarding a GDPR Article. Commentaries should not exceed 4000 words total (including abstract, main text, references and figure legends). They should have an abstract of 50 words or less ("Overview") and no more than 35 references.

Writing your Commentary Article

Overview

Commentary begins with an introductory paragraph that immediately presents the issues under discussion in a way that captures the reader's interest. The Overview should be general enough to orient the reader not familiar with the specifics of the field being discussed. Here, and throughout the article, the author should avoid the jargon and special terms of his or her field or system.

Body of the text

The body of the text should, in the limited space available, develop the discussion in a lively manner. By "lively" we don't mean hype and oversimplification. Rather, the editors seek clear, declarative writing that avoids the passive tense, tangled constructions, and needless detail. Avoid asides that interrupt the flow of the text.

Commentary structure

In general, the commentary should follow the structure of the Article. We prefer an analytical approach. This means that, if possible, we analyse the meaning of the most important sentences included in each paragraph of the Article, and then we move on to the next one, with the same approach. That said in general terms, it is also true that we don't need to be that analytical all the time. In other words, if a paragraph is terribly boring or does not deserve more than five minutes of your time, you don't need to split hairs. A general headline will work just fine.

Article 12 makes a good example. The provision is made of 8 paragraphs and each one of them is commented (check the index of contents, here). However, certain paragraphs (for example 1 and 5) require deeper analysis while others can be grouped in a more general "issue", without further analysis.

Paragraph numbering

The Wiki automatically numbers paragraphs once they are given a hierarchy value ("Heading", "Sub-heading 1", "Sub-heading 2", etc). Therefore, there is no need to give a number to each paragraph. If doing so helps you in visualising the structure of the Commentary, do it. Please, remember that no numbers should be given to the paragraphs once the commentary is uploaded on the GDPRhub.

Citation Style

• Books (monographies)
  • surname(s) of author(s),
  • full title,
  • publisher and year in brackets,
  • page.

Example: Endicott, Administrative Law (OUP 2009), p. 10.

• Commentaries
  • surname of author(s) in italics. (if applicable), in
  • editor(s) (if applicable),
  • full title,
  • Article,
  • margin number (or page if applicable)
  • publisher and year in brackets (you may need to also cite 'Edition')
  • (if online, provide date of access)

Example (paper): Leupold, Schrems, in Knyrim, Der Datkomm, Article 80 GDPR, margin number 49 (Manz 2018).

Example (paper): Docksey, in Kuner et el., The EU General Data Protection Regulation (GDPR), Article 68 GDPR, p. 1046 (Oxford University Press 2020).

Example (online): Klabunde, in Ehman, Selmayr, Datenschutz-Grundverordnung, Article 67 GDPR, margin number 16 (Beck 2018, 2nd ed.) (accessed 22.4.2021)

• Journal papers
  • surname(s) author(s),
  • full title, in
  • full name of the journal,
  • volume number (if available),
  • (year),
  • page or page numbers.
  • (if online, provide link and date of access)

Example: Alison Young, In Defence of Due Deference, in Modern Language Review, 72, (2009), p. 554.

• EDPB/DPAs guidelines, opinions --> name of the authority (EDPB, CNIL, etc.), title, date, page number

Example: EDPB, Guidelines 05/2020 on consent under Regulation 2016/679, 4 May 2020, p. 12.

• EDPB, DPA, Court decisions --> name of the authority, date, parties, case number, relevant paragraphs (if possible) + link to the GDPRhub summary (if available) [if not available, link to the official decision or reference to the book or journal that features the decision]
  • Example: CJEU, 12.7.2005, Schempp, C-403/03, § 19 (available here [LINK])

Practical tips

• Please, always cite the full work in each footnote. In other words, do not use "op. cit", "ibid", "Idem" and similar;
• Where there are two authors, both should be named; with three or more only the first author's name plus "et al." need be given.
• Do not use footnotes in your word draft. It will be easier for you to upload the file in the Hub and use the "Cite" feature on the Wiki.

Example: "Articles 39(1)(d) and (e) lay down the DPO’s obligations in relation to the supervisory authorities. For example, the DPO could facilitate cooperation of the organisation in prior consultation procedures or DPA investigations. [6. Klabunde, in Ehman, Selmayr, Datenschutz-Grundverordnung, Article 67, Rn 16 (Beck 2018, 2nd ed.) (accessed 22.4.2021)]"