ISSUES OF CONSISTENCY AND COMPLEMENTARITY IN EU PRIVACY LAW: THE EUROPOL'S BIG DATA CHALLENGE

Under the Maastricht Treaty, the introduction of data protection rules in EU freedom, security, and justice instruments was justified by the pillars structure. A new EU competence regulating personal data protection and its free movement enabled overcoming the reticence about framing the processing activities for police and judicial cooperation in criminal matters. Despite adopting the law enforcement directive, Europol maintained a distinct regulation until regulation 2022/991 aligned its mandate with the EU data protection regulation (EUDPR). These amendments faced the European Data Protection Supervisor's criticism for departing from the horizontal standards set down in the EUDPR, Chapter IX. This paper highlights legal uncertainty over fragmented legal frameworks on personal data protection in the EU and clarifies their relationships, stressing the importance of coherence among Union policies, while taking the Europol's big data challenge episode under scrutiny.