Developments

Brussels, 14 April - During its April 2025 plenary, the European Data Protection Board (EDPB) has adopted guidelines on processing of personal data through blockchain technologies.  A blockchain is a distributed digital ledger system that can confirm transactions  and  establish  who  owned  a  digital  asset  (such  as cryptocurrency)  at  a  given  time. Blockchains can also support the secure handling and transfer of data, ensuring its integrity and traceability. As the use of blockchain technologies is expanding, the Board considers it important to help organisations using these technologies to comply with the GDPR. In its guidelines, the EDPB explains how blockchains work, assessing the different possible architectures and their implications for the processing of personal data. The guidelines highlight the importance of implementing technical and organisational measures at the earliest stages of the design of the processing. The EDPB also clarifies that the roles and responsibilities of the different actors in a blockchain-related processing of personal data should be assessed during the design of the processing.In addition, organisations should carry out a Data Protection Impact Assessment (DPIA) before processing personal data through blockchain technologies, where the processing is likely to result in a high risk to the rights and freedoms of individuals. According to the Board, organisations should also ensure the highest protection of individuals’ personal data during the processing so that they are not made accessible to an indefinite number of persons by default. The guidelines provide examples of different techniques for data minimisation, as well as for handling and storing personal data. As a general rule, storing personal data in a blockchain should be avoided if this conflicts with data protection principles. Finally, the Board highlights the importance of the rights of individuals especially regarding transparency, rectification and erasure of personal data.  The guidelines will be subject to public consultation until 9 June 2025, providing stakeholders with the opportunity to comment. During its latest plenary, the EDPB also decided to closely cooperate with the AI Office in relation to the drafting of the guidelines on the interplay between the AI Act and EU data protection legislation. 

Brussels, 14 March - During its March 2025 plenary meeting, the European Data Protection Board (EDPB) adopted a statement on the implementation of the Passenger Name Record Directive (PNR) in light of the Court of Justice of the EU (CJEU) judgment C-817/19*.  In its second statement on the implementation of the PNR Directive, which follows the one of 15 December 2022, the Board gives further guidance to the Passenger Information  Units (PIUs)** on the necessary adaptions and limitations to the processing of PNR data, following the PNR judgment. PNR data is personal information provided by passengers, and collected and held by air carriers that includes the names of the passengers, travel dates, itineraries, seats, baggage, contact details and means of payment. The statement includes practical recommendations for the national laws transposing the PNR Directive in order to give effect to the findings of the CJEU in the PNR judgment. The recommendations cover some of the key aspects of the PNR judgement such as how European countries should select the flights from which PNR data is collected, or how long PNR data should be retained. According to the Board, the retention period of all PNR data should not exceed an initial period of six months. After this period, European countries may only store PNR data as long as needed and proportionate to the objectives of the PNR Directive. EDPB Chair Anu Talus said: “The EDPB recognises the importance of the PNR Directive in improving the security of passengers across Europe and in helping prevent, detect and prosecute terrorist offences and serious crime. The transfer of PNR data in Europe should take place in a harmonised way and in full respect of data protection principles.” The Board is aware that some European countries have already started the adaptation process, but there is still a substantial lack of implementation efforts throughout the Member States. Therefore, in its statement, the EDPB outlines the urgent need to implement the necessary changes and to amend national laws by taking into account the PNR judgment as soon as possible.   Note to editors* On 21 June 2022, on a referral from the Belgian Constitutional Court, the CJEU rendered its judgment C-817/19 on the use of passenger name record (PNR) data for the prevention, detection, investigation and prosecution of terrorist offences and serious crime, under the PNR Directive 2016/681. While the Court found that the validity of the PNR Directive was not affected, it ruled that, in order to ensure compliance with the EU Charter of Fundamental Rights (the Charter), the PNR Directive needs to be interpreted as including important limitations to the processing of personal data. Some of these limitations are the application of the PNR system only to terrorist offences and serious crime, having an objective link with the carriage of passengers by air, and the non-indiscriminate application of the general retention period of five years to all passengers’ personal data.** The PIUs are specific entities in European countries which are responsible for the collection, storage, and processing of PNR data. 

Brussels, 05 March - The European Data Protection Board (EDPB) has launched its Coordinated Enforcement Framework (CEF) action for 2025. Following a year-long coordinated action on the right of access in 2024, the CEF's focus this year will shift to the implementation of another data protection right, namely the right to erasure or the “right to be forgotten” (Art.17 GDPR). The Board selected this topic during its October 2024 plenary as it is one of the most frequently exercised GDPR rights and one about which DPAs frequently receive complaints from individuals.  Next steps During 2025, 30 Data Protection Authorities (DPAs) across Europe, as well as the European Data Protection Supervisor (EDPS), will take part in this initiative. Participating DPAs will soon contact a number of controllers from different sectors across Europe, either by opening new formal investigations or doing fact-finding exercises. In the latter case, they might also decide to undertake additional follow-up actions if needed.  DPAs will check how controllers handle and respond to the requests for erasure that they receive and, in particular, how they apply the conditions and exceptions for the exercise of this right.  DPAs will also stay in close contact to share and discuss their findings throughout this year. The results of these national actions will be aggregated and analysed together to generate deeper insight into the topic, allowing for targeted follow-ups on both national and EU levels.  Background The CEF is a key action of the EDPB under its 2024-2027 strategy, aimed at streamlining enforcement and cooperation among DPAs.In the past three years, three previous CEF actions on different topics were carried out:  the use of cloud-based services by the public sector, the designation and position of Data Protection Officers, and the implementation of the right of access by controllers.   For further information: AT DPA: Coordinated Enforcement Framework 2025 (CEF 2025) - EDSA BG DPA: Започва координирано действие по изследване на приложението на правото на изтриване (право „да бъдеш забравен“) DA DPA: EDPB igangsætter koordineret indsats om retten til sletning DE DPA (Baden-Wuerttemberg): Europaweite Aktion zum Recht auf Löschung DE DPA (Berlin):  PRESSEMITTEILUNG der Konferenz der unabhängigen Datenschutzaufsichtsbehörden des Bundes und der Länder vom 5. März 2025 DE DPA (Brandenburg): Brandenburgische Datenschutzaufsicht beteiligt sich an europaweiter Prüfung zum Recht auf Löschung mit Schwerpunkt Wohnungsunternehmen EDPS: EDPS participates in fourth Coordinated Enforcement Action: focus on the right to erasure of personal data EL DPA: Έναρξη συντονισμένης δράσης του ΕΣΠΔ 2025 σχετικά με το δικαίωμα διαγραφής ES DPA: La AEPD participa en una acción europea para analizar la aplicación del derecho de supresión FI DPA: Tietosuojavaltuutetun toimisto selvittää henkilötietojen poisto-oikeuden toteutumista osana EU:n laajuista toimenpidettä HR DPA: Započela nova koordinirana akcija EDPB-a: pravo na brisanje IE DPA: Launch of coordinated enforcement action on the right to erasure IT DPA: GDPR, il Garante italiano partecipa al CEF 2025 sul diritto alla cancellazione LI DPA: Europäische Initiative zum Recht auf Löschung MT DPA: Launch of Coordinated Enforcement Action on the Right to Erasure SI DPA: Informacijski pooblaščenec bo v letu 2025 nadzoroval upoštevanje pravice do izbrisa

Brussels, 13 February - The EDPB published the Coordinated Supervision Committee's (CSC) biannual activity report (July 2022 - December 2024). Over the last two years, the CSC worked on the integration of the large-scale EU information technology (IT) systems within its scope. During the reporting period, it took over the supervision of the upgraded Schengen Information System (SIS) and the Visa Information System (VIS). In addition, the Committee prepared for the arrival of new systems and for the implementation of interoperability regulations. The Committee has also published a set of recommendations on the Internal Market Information System (IMI) transparency obligations for data controllers. In addition, in July 2023, the CSC published ‘Europol’s information systems - a guide for exercising data subjects’ rights: the right of access, rectification, erasure and restriction’. Following the 2022 Audit Report of the EDPS on Europol’s processing of personal data of minors under 15 years old, provided to Europol by third countries and international organisations and marked as suspects, the CSC undertook a coordinated activity to analyse the input from several Member States. During the past two years, the Committee also promoted dialogue and engagement with stakeholders, particularly with civil society.   Update: Brussels, 27 February - The CSC has also adopted its work programme 2025-2026. To ensure a continuous high level of protection of individuals’ rights, the Committee will dedicate closer attention to following topics: allocation of roles (controller, joint controller, processor) in the systems falling under the Justice and Home Affairs (JHA) interoperability framework streamlined cooperation when handling complaints (JHA interoperability framework and Europol, Eurojust, European Public Prosecutor’s Office).   CSC’s future work Looking forward to the coming years, the CSC is ready to welcome more EU IT systems and EU bodies, offices or agencies within its scope. As the range of the CSC’s activities continues to expand, the Committee will keep its organisation and operation under constant review to ensure an effective and efficient supervision. In addition, the CSC will continue to assist national data protection authorities (DPAs) in their work, by providing further clarification on the interpretation of EU and national laws. The Committee will also foster the exchange of information and best practices, and provide support for joint audits and coordinated inspections. Taking advantage of its unique framework and broad perspective, the CSC will ensure the proper monitoring of multiple data flows among systems, transversal interactions and sharing of information between EU agencies and bodies. To this end, and to guarantee a high level of data protection, the Committee will keep developing coordinated supervisory activities.   Background The CSC is a group of DPAs, which together ensure coordinated supervision of large scale IT systems, and of EU bodies, offices and agencies falling under its scope. The CSC enjoys an autonomous functioning and positioning and it adopts its own rules of procedure and working methods. The Committee was established within the framework of the EDPB. 

Brussels, 12 February - During its February 2025 plenary meeting, the European Data Protection Board (EDPB) adopted a statement on age assurance and decided to create a taskforce on AI enforcement. In addition, the Board also adopted recommendations on the 2027 World Anti-Doping Agency (WADA) World Anti-Doping Code. In a statement on age assurance, the EDPB lists ten principles for the compliant processing of personal data when determining the age or age range of an individual. The statement aims to ensure a consistent European approach to age assurance, to protect minors while complying with data protection principles.  EDPB Chair Anu Talus said: “Age assurance is essential to ensure that children do not access content that is not appropriate for their age.  At the same time, the method to verify age must be the least intrusive possible and the personal data of children must be protected. The principles put forward by the EDPB will help the industry to assess an individual’s age in a way that is compliant with data protection principles, while protecting children’s wellbeing.” The EDPB is also cooperating with the European Commission on age verification in the context of the Digital Services Act (DSA) working group. During the plenary, the Board also decided to extend the scope of the ChatGPT task force to AI enforcement. In addition, the EDPB members underlined the need to coordinate DPAs' actions regarding urgent sensitive matters and for that purpose will set up a quick response team.  EDPB Chair Anu Talus said: “The GDPR is a legal framework that promotes responsible innovation. The GDPR has been designed to maintain high data protection standards while fully leveraging the potential of innovation, such as AI, to benefit our economy. The EDPB’s task force on AI enforcement and the future quick response team will play a crucial role in ensuring this balance, coordinating the DPAs' actions and supporting them in navigating the complexities of AI while upholding strong data protection principles.” During the plenary, the EDPB also adopted recommendations on the 2027 WADA World Anti-Doping Code. When processing personal data for anti-doping purposes, it is essential to respect and safeguard the personal data of athletes. In many cases, this will involve the processing of sensitive personal data, such as health data derived from biological samples. The EDPB’s main objective is to assess the compatibility of the WADA Anti-doping Code and International Standard for Data Protection (ISDP) with the GDPR. The Anti-doping Code and Standards should hold the National Anti-Doping Organisations (NADOS) subject to a standard equivalent to that of the GDPR when processing personal data for anti-doping purposes. The EDPB’s recommendations address key principles of data protection, such as the need for an appropriate legal basis for the processing of personal data and purpose limitation. The recommendations also address the fact that individuals need to be fully informed about the processing of their personal data and can effectively exercise their rights.   Note to editors:The recommendations on the 2027 World Anti-Doping Agency (WADA) World Anti-Doping Code, adopted during the EDPB Plenary, are subject to the necessary legal, linguistic and formatting checks and will be made available on the EDPB website once the process has been completed.