Confindustria took part on the public consultation on the Guidelines on the processing of personal data for scientific research purposes, adopted by the European Data Protection Board (EDPB).

Confindustria’s response to the consultation highlights the need for a clear, proportionate and uniform interpretative framework for the GDPR at European level, capable of supporting industrial research, experimental development and innovation, without compromising the level of protection of fundamental rights.

Confindustria welcomes the overall approach of the Guidelines, which embraces a broad concept of scientific research, including activities carried out by private entities, even where these may have commercial objectives.

At the same time, comments and proposals are put forward on certain aspects of particular importance to businesses, including the criteria for classifying scientific research, the application of legitimate interest as a legal basis for processing, the use of general and dynamic consent, the processing of special categories of data, the definition of data protection roles in complex projects, and safeguards formerly Article 89 of the GDPR, the DPIA and the use of anonymisation and pseudonymisation techniques.