Association of German Supervisory Authorities issues paper on broad consent for research
On April 3, 2019, the Association of German Supervisory Authorities (“Datenschutzkonferenz” or “DSK”) issued a paper on the interpretation of “broad consent” for scientific research in Recital 33 of the GDPR and the interplay with the definition of consent and the principle of purpose limitation.
According to the DSK, broad consent should only be used in exceptional circumstances when it is not possible to establish at the outset the expected scope of the research. Moreover, the DSK suggests that a broad consent can be fixed at a later stage of the research by narrowing down the scope of the research once that scope is clearer – i.e., deliberately not using the obtained flexibility.
Ful article: Association of German Supervisory Authorities issues paper on broad consent for research