CIPP/E Study Guide
IAPP Training · Module 1 - BoK I.B

Module 1 · Council of Europe vs the EU

A critical exam distinction. The European Union (EU) is an economic and political union of 27 Member States; the Council of Europe (CoE) is an international organisation of 46 Member States with no legislative power of its own. All 27 EU states are in the Council of Europe, but not vice versa. The European Court of Human Rights (ECtHR) (Strasbourg) belongs to the CoE, not the EU.

The European Union (EU) is an economic and political union of 27 Member States (the UK exited on 1 Jan 2020, dropping it from 28 to 27). Its privacy instruments include the Charter of Fundamental Rights of the EU (CFREU) - sometimes called the "constitution of the EU" - the TFEU, the Lisbon Treaty, the GDPR and the ePrivacy Directive.

The Council of Europe (CoE) is an international organisation (NOT an EU body) of 46 Member States. Its mission is to "promote democracy, human rights and the rule of law." It has no legislative ability of its own but influences law through conventions and treaties members agree to. The CoE developed the ECHR, the ECtHR and Convention 108.

Council of Europe vs European Union
Council of Europe (CoE)European Union (EU)
TypeInternational organisation (not an EU body)Economic and political union
Members46 Member States27 Member States (28 before Brexit)
RolePromote democracy, human rights, rule of law; no legislative power of its ownMakes directly binding law (e.g. the GDPR)
Key instrumentsECHR, Convention 108, creates the ECtHRCFREU, TFEU, Lisbon Treaty, GDPR, ePrivacy Directive
CourtEuropean Court of Human Rights (ECtHR) - StrasbourgCourt of Justice of the EU (CJEU) - Luxembourg
Common exam trap

All 27 EU Member States are members of the Council of Europe, but not vice versa. The ECtHR is not part of the EU; it examines data protection via Article 8 ECHR.

Key terms - quick answers

What is “European Union (EU)”?
Economic and political union of 27 Member States; its privacy instruments include the CFREU, TFEU, GDPR and ePrivacy Directive.
What is “Council of Europe (CoE)”?
International organisation of 46 Member States that promotes democracy, human rights and the rule of law; not an EU body and has no legislative power of its own.
What is “Convention 108”?
Legally binding Council of Europe treaty (1981) on automatic processing of personal data.
What is “Charter of Fundamental Rights of the EU (CFREU)”?
EU instrument, made binding by the Treaty of Lisbon, in light of which EU data protection law is interpreted.