Secondary Data Use | New EDPB Study

4 April 2025

The EDPB has published a commissioned study on the secondary use of personal data in scientific research. Haven’t had time to read it yet? No worries - MyData-TRUST’s team of experts is here to break it down and help you understand what it means for the use of personal data in science Find the full study here.

The first question is: what is a commissioned study?

The EDPB has the power to commission studies on specific topics from external contractors, which are then published on the EDPB website (link). So far, there have been two studies concerning scientific research: One on the appropriate safeguards under Article 89(1) GDPR and the recently published one.

While the EDPB expressly states that these studies don’t represent its views, this new study contains certain recommendations on the subject, which are particularly relevant given the lack of official guidance.

Key insights

The study highlights several elements necessary to assess the issue of secondary use by analysing relevant international conventions and recommendations, the GDPR itself, and the guidance provided by national or sectoral legislation. The key aspects of the analysis are:

This study and its recommendations shed light on the complexity of interpreting the rules applicable to the secondary use of personal data in scientific research, including clinical trials. At MyData-TRUST, we specialize in this area and monitor all developments in this field, our clients have the guarantee of being supported by experts with both scientific and legal background to navigate these regulatory constraints.

If you are in any doubt, please contact us at [email protected]