During 2021, GDPR Article 61 mutual assistance requests were received by the DPC from the Dutch and the French data protection authorities. Each of these requests sought the DPC to further investigate a number of concerns relating to TikTok’s processing of its users’ personal data, particularly child users.

The authorities concerned had been investigating TikTok prior to the company locating its main establishment (EU headquarters) in Ireland in July 2020, following which in December 2020 the DPC assumed the role of TikTok’s lead supervisory authority once other EU supervisory authorities had satisfied themselves TikTok was main- established in Ireland .

As a result, the Dutch and French authorities concluded that they no longer had competence to investigate TikTok and accordingly transferred their investigation files, requesting the DPC to investigate further . These investi- gations coupled with the DPC’s own identification of key concerns through active engagement with TikTok in 2021 led the DPC to commence two own-volition inquiries pursuant to Section 110 of the Data Protection Act 2018 in relation to TikTok compliance with requirements of the GDPR .