Gathering feedback on draft guidelines on interplay between DMA and GDPR (digital-markets-act.ec.europa.eu)

🤖 AI Summary
The European Commission and the European Data Protection Board (EDPB) have opened a public consultation on draft guidelines clarifying how the Digital Markets Act (DMA) and the General Data Protection Regulation (GDPR) interact. The guidance—prepared by DG Competition and DG CONNECT in collaboration with the EDPB since September 2024—focuses on DMA provisions that implicate personal data, notably data combination and portability, and measures around alternative app stores and distribution channels. Stakeholders can comment until 4 December 2025; the Commission and EDPB plan to adopt final guidelines in 2026. For the AI/ML community this is consequential: the rules will shape when and how cross-platform data can be combined or ported into models, the lawful bases and transparency obligations that apply, and how gatekeepers may impose “strictly necessary and proportionate” technical or contractual measures without breaching GDPR. Practically, expect clarified expectations on controllers vs processors, consent vs other legal bases for reuse, data protection impact assessments, and interoperability/APIs for data transfers. The guidance aims to reduce legal uncertainty for businesses building ML systems or deploying models via alternative app stores, while ensuring personal data processing remains compliant with EU data-protection law.
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