EDPB Guidelines on scientific research processing

Guidelines 1/2026 on processing of personal data for scientific research purposes

The guidelines clarify what qualifies as scientific research under the GDPR's specific, flexible provisions and set out six key indicative factors for assessing whether processing is genuinely motivated by scientific research — including a methodical approach, ethical standards, verifiability, autonomy, societal objectives, and novel contribution to knowledge. They address the presumption of compatibility for further processing of previously collected data for research, the distinction between broad and dynamic consent for research whose exact purposes are not yet known, transparency obligations toward research participants, and the restrictive, case-by-case conditions under which erasure or objection requests may be rejected where they would seriously impair a research project.