It is not clear if reddit has already engaged in this with Google, or if it is something that’s only starting. However, as outlined in my post, they might have to consult with a DPA before engaging in this anyway, which I doubt they have done. So, no, DPAs are absolutely the right place to make that complaint.
Even if they hadn’t started yet, might as well get their eyes on it, and force them to do it right from the get go (which they cannot do, as it currently stands).
You really believe a large Corp like reddit decided on something as big as this without consulting with their lawyers? Fuck spez, but there’s no way not a single lawyer working with reddit remembered the massive legislation that has by far had the largest impact on the internet in years.
Corporate lawyers tend to be …optimistic. And then management will put a risk calculation on top of that. As a result, most larger companies violate the GDPR. See the popular use of Google Analytics or Microsoft 365, for example, which are illegal in the EU, if you ask a DPA¹. Giving them a reality check is never a bad idea.
¹) https://www.imy.se/en/news/four-companies-must-stop-using-google-analytics/
https://news.itsfoss.com/microsoft-office-365-illegal-germany/
Especially US companies usually just do things and are willing to engage in lenghty legal battles after the fact.they are very, very litigous.
Another issue to consider is that the GPDR is held vague on purpose since it applies to your neighborhood yoga studio as well as Google or reddit. Entirely different use cases. So there is a lot of room for interpretation.
Looking at the conduct just within Europe, yes, I think it is possible GDPR considerations were either ignored or downplayed to the point of irrelevance. There was a recent study by noyb.eu which showed that DPOs are still often pressured to make recommendations that do not align with GDPR principles.
Either way, the DPAs will have to decide if the complaint has merit. Given new technologies are specifically mentioned im the GDPR, I am at least very curious to see how it turns out.
