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ARTICLE · 17 NOVEMBER 2025

EU Data Act: Interplay With The GDPR

Addleshaw Goddard
Addleshaw Goddard
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Addleshaw Goddard

Addleshaw Goddard

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The EU Data Act introduces sweeping obligations for data access and reuse, especially in mixed datasets combining personal and non-personal data.

European UnionPrivacy

The EU Data Act introduces sweeping obligations for data access and reuse, especially in mixed datasets combining personal and non-personal data. While both the Data Act and GDPR share principles like transparency and fairness, their objectives diverge: the GDPR protects personal data, while the Data Act promotes data sharing. Navigating both requires careful data classification, lawful processing bases, and robust contractual safeguards. Though GDPR generally prevails in case of conflict, the Data Act sometimes complements it - especially in IoT contexts. Enforcement will be split across national authorities, adding complexity to compliance.

In the previous part of our Data Act series, we explored how the EU Data Act (Regulation (EU) 2023/2854) “Data Act” establishes new frameworks to transform the way organizations handle data, creating new compliance obligations while opening up substantial opportunities across both consumer and industrial data ecosystems.

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