This third paper in our series analyzing the Digital Markets Act assess the operational consequences of the DMA obligations for gatekeepers and organizations receiving or getting access to personal data, specifically in the context of Art. 6(9) of the DMA.
The article mandates the portability of data provided or generated by a user from a gatekeeper organization to the end-user directly or a third party authorized by the end-user. This raises a number of questions regarding privacy and security with respect to the data in scope of the DMA obligations.
The paper recommends solutions towards enabling the DMA’s policy objectives without compromising privacy rights, obligations or the security of individuals and the DMA aim to increase competitiveness.
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