In this response, CIPL welcomes the European Data Protection Board’s (EDPB) contribution towards more legal certainty in an area of fundamental importance to European societal and economic progress – research. In light of persistent fragmentation in national interpretation, clear and workable guidance with respect to the processing of personal data in the context of research benefits researchers, research institutions, life sciences companies, and the many other organisations that process personal data for scientific research, whether on a public, academic, non-profit, or commercial basis.
Our comments are offered in a constructive spirit, with the aim of ensuring that the Guidelines enable responsible and beneficial research within the established framework guiding scientific research, while maintaining robust protection for data subjects.
For more than twenty years, CIPL has advocated for a risk-based and accountability-driven approach to data protection, and our recommendations are grounded in that approach.
