The German Conference of Independent Supervisory Authorities (“DSK”) published on March 23, 2022 a statement on scientific research and data protection (see here, in German).  The DSK published the statement in response to the German Government’s initiative on a general law on research data as part of its Open Data Strategy, announced on July 6, 2021.  The DSK also refers to the Government’s intention to introduce a law on the use of health data, including the storage of data in electronic health records.

According to the DSK, the GDPR aims to strike a balance between, on the one hand, freedom of research and, on the other hand, the right to data protection.  In particular in relation to the purpose limitation principle, the DSK recognizes that the GDPR reflects a political choice of the EU to foster scientific advancements and strengthen the Union’s economic and technological foundations, to create a European science area.

The DSK emphasizes the importance of the GDPR’s principle of data minimization in scientific research.  It provides that entities performing scientific research should rely as much as possible on de-identification methods such as anonymization, pseudonymization, and data custodianship.

Finally, the DSK announced that it will be providing “constructive advice” on national and EU legislative developments that aim to create an open health data space, including by publishing statements or papers in the “near future”.

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Photo of Kristof Van Quathem Kristof Van Quathem

Kristof Van Quathem advises clients on information technology matters and policy, with a focus on data protection, cybercrime and various EU data-related initiatives, such as the Data Act, the AI Act and EHDS.

Kristof has been specializing in this area for over twenty…

Kristof Van Quathem advises clients on information technology matters and policy, with a focus on data protection, cybercrime and various EU data-related initiatives, such as the Data Act, the AI Act and EHDS.

Kristof has been specializing in this area for over twenty years and developed particular experience in the life science and information technology sectors. He counsels clients on government affairs strategies concerning EU lawmaking and their compliance with applicable regulatory frameworks, and has represented clients in non-contentious and contentious matters before data protection authorities, national courts and the Court of the Justice of the EU.

Kristof is admitted to practice in Belgium.

Photo of Lars Lensdorf Lars Lensdorf

Lars Lensdorf is a partner in the Frankfurt office. He focuses on IT law, outsourcing, cloud-services, digitalization/ industry 4.0, IT related bank regulatory matters, IT-compliance, incl. cybersecurity and data protection.

Furthermore, Lars is also focused on interfaces to other practice areas to the…

Lars Lensdorf is a partner in the Frankfurt office. He focuses on IT law, outsourcing, cloud-services, digitalization/ industry 4.0, IT related bank regulatory matters, IT-compliance, incl. cybersecurity and data protection.

Furthermore, Lars is also focused on interfaces to other practice areas to the extent that IT related matters are affected, e. g. regulatory requirements for banking and financial services as well as public procurement law.

Photo of Anna Sophia Oberschelp de Meneses Anna Sophia Oberschelp de Meneses

I advise companies across the EU on technology laws, with a focus on data protection, cybersecurity, and current consumer protection laws. I help businesses navigate complex regulations like the GDPR, AI Act, Digital Services Act, Unfair Commercial Practices Directive, and the upcoming Digital…

I advise companies across the EU on technology laws, with a focus on data protection, cybersecurity, and current consumer protection laws. I help businesses navigate complex regulations like the GDPR, AI Act, Digital Services Act, Unfair Commercial Practices Directive, and the upcoming Digital Fairness Act, turning legal requirements into practical, business-friendly solutions.

In data protection, I support tailored GDPR compliance, international data transfers, and privacy-conscious marketing. On cybersecurity, I guide clients through risk assessments, incident response, and evolving laws such as NIS2 and the Cyber Resilience Act. Regarding consumer protection, I advise on existing laws to help businesses revise their terms and conditions for compliance and review online interfaces to ensure all mandatory consumer information is clearly provided, tackling issues like dark patterns and unfair contract clauses.

Fluent in multiple languages and experienced across borders, I’m passionate about helping clients embed compliance into their operations and thrive in the fast-changing digital landscape.