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Privacy Next’s Feedback to the European Data Protection Board’s Guidelines 1/2026 on the processing of personal data for scientific research purposes

On 16 April 2026, the EDPB adopted Guidelines 1/2026 on the processing of personal data for scientific research purposes and called for feedback on the Guidelines. There is no question that there is a need for greater clarity on when GDPR applies to scientific research. However, the present Guidelines were developed before the legislative debate surrounding the Digital Omnibus and the future scope of scientific research has reached a conclusion. In its feedback to the EDPB, Privacy Next asserts that the present Guidelines should be withdrawn and reconsidered once the co-legislators have concluded the Digital Omnibus negotiations. The role of the regulator is to apply agreed laws within an established mandate, not to pre-empt the legislative process.