Science Europe - Simple Science Europe Feedback on the Implementation of the GDPR Brussels, 8 February 2024 Introduction Science Europe welcomes the opportunity to provide feedback on the implementation of the General Data Protection Regulation (GDPR) through the call for evidence opened for the 2025 GDPR report. [...] Separate Controlling The main challenges are: • Differing interpretations of the rules related to controlling and processing data • Lack of common understanding of roles and responsibilities under GDPR The rules around controlling and processing data are interpreted differently by different organisations. [...] Several factors must be considered to establish the appropriate agreement, including the nature of the shared data, the appropriate legal basis, the respective data flows, and the different roles fulfilled by the various partners. [...] To tackle these challenges, Science Europe calls on the European Commission, EU Council, and European Data Protection Board to: • Review and, where necessary, update the available guidelines to communicate more clearly the definition, applicability, and requirements of joint and separate controlling, to harmonise the interpretations of the relevant GDPR provisions. [...] To address this, Science Europe recommends that the European Commission, EU Council, and European Data Protection Board: 2 SCIENCE EUROPE FEEDBACK ON THE IMPLEMENTATION OF THE GDPR • Support the development of sector-specific Codes of Conduct that would address the needs of research and innovation in international collaboration contexts.
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