In a position paper dated April 1, 2019 (Positioning on responsibility and accountability for Facebook fanpages and supervisory responsibility.) take the view that the Shared responsibility agreement provided by Facebook did not meet the requirements of Art. 26 GDPR for such agreements. With this agreement, Facebook had relied on the judgment of the ECJ in which the ECJ surprisingly qualified page operators and Facebook as jointly responsible parties.
The opinion of the DSK would have the consequence that the operation of Facebook fanpages is currently not possible in a legally compliant manner, within the scope of application of the GDPR.