Article 5

2a. In Article 5, the following paragraph 2a is inserted:

2a. In Article 5, the following paragraph is added:

Justification

INNOVATION PACKAGE #1: Makes the GDPR’s broad protection more proportionate in practice. It clarifies that principles, guidance, complaints and enforcement must reflect actual risk, legal certainty and the balance required by Recital 4. Supervisory authorities and the EDPB should prioritise serious infringements, coordinate with sectoral regulators, involve stakeholders and avoid guidance that creates new obligations. A Data Protection Data Space improves transparency, evidence-based supervision and consistent application across the Union.

In Article 5, the following paragraph 3 is added

2a. Article 5, paragraph 2 is amended as follows

2b. In Article 5, paragraph 2 is amended:

2. The controller shall be responsible for, and be able to demonstrate compliance with, paragraph 1 (‘accountability’). When assessing compliance with the accountability obligation, appropriate governance structures, in particular, the appointment of a data protection officer in accordance with Article 37, shall be taken into account."

Justification

DPO Package #1: The amendment strengthens accountability by recognising DPOs as practical governance safeguards and first points of contact for complaints. DPOs already advise controllers and processors, monitor compliance and support data subjects; giving them an explicit complaint-handling role makes resolution faster, less bureaucratic and closer to the facts. Voluntary or shared DPOs are encouraged. Supervisory authorities remain available where the complaint is not addressed or not fully remedied within one month.

2b. After Article 5, paragraph 3, the following subparagraph is added

2d. Article 5, paragraph 1, point c is deleted:

1. Personal data shall be:"

2. Article 5 (1)(b) is replaced by the following: ‘collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall, in accordance with Article 89(1), be considered to be compatible with the initial purposes, independent of the conditions of Article 6(4) of this Regulation, (‘purpose limitation’);’

collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes or for the development, training, testing, validation or use of new technical solutions based on aggregated data, including AI systems and AI models, subject to the safeguards in Article 88c and without prejudice to Article 9 shall, in accordance with Article 89(1), be considered to be compatible with the initial purposes, independent of the conditions of Article 6(4) of this Regulation, (‘purpose limitation’);

Justification

Data collected for one purpose can be reused for research, statistics, archiving, or for training, testing, or using AI systems on data from which individuals are not identifiable, and this reuse is deemed compatible with the original purpose (so no separate legal basis is needed under Art. 6(4)), provided the Article 88c safeguards apply and it doesn’t override Article 9 (special category data protections).

collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall, in accordance with Article 89(1),only be considered to be compatible with the initial purposes, independent ofwhen the conditionsrequirements of Article 6(4) and guarantees of thisArticle Regulation89(1) have been met. General product development as well as the training, testing or validation of general AI systems or AI models shall not be considered compatible purposes solely on the basis of their designation as research (‘purpose limitation’);’

Justification

Purpose limitation is a core principle of informational self-determination. A research label shall not replace testing.

collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall, subject to the application of appropriate safeguards in accordance with Article 89(1) and the principle of lawfulness, be considered to be compatible with the initial purposes, independent of the conditions of Article 6(4) of this Regulation, (‘purpose limitation’);

collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall, in accordance with Article 89(1), be considered to be compatible with the initial purposes, independent of the conditions of Article 6(4) of this Regulation, (‘purpose limitation’);

collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall, in accordance with Article 89(1), be considered to be compatible with the initial purposes, independent of the conditions of Article 6(4) of this Regulation, (‘purpose limitation’);

collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall, in accordance with Article 89(1), not be considered to be compatibleincompatible with the initial purposes, independent of the conditions of Article 6(4) of this Regulation, (‘purpose limitation’);’

Justification

Reinstatement of the currently valid text of the Regulation.

‘collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall, subject to the implementation of appropriate safeguards in accordance with Article 89(1), be considered to be compatible with the initial purposes, independent of the conditions of Article 6(4) of this Regulation, (‘purpose limitation’);’