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ARTICLE · 15 APRIL 2026

Scientific Research Under GDPR: EDPB Sets New Boundaries

Goodwin Procter LLP
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The European Data Protection Board has published draft guidelines clarifying how the GDPR applies to scientific research, addressing longstanding uncertainties around data processing flexibilities, consent models, and compliance requirements. These guidelines establish six key factors for qualifying as genuine scientific research and outline when organisations can benefit from research-specific derogations under EU data protection law.

European UnionPrivacy
Curtis McCluskey
Curtis McCluskey
Rebecca Gray
Rebecca Gray

On 15 April 2026, the European Data Protection Board (EDPB) published draft Guidelines on the processing of personal data for scientific research (Guidelines), marking a significant step towards greater consistency in the application of the General Data Protection Regulation (GDPR). Echoing its commitment in last year’s Helsinki Statement on Enhanced Clarity, the EDPB seeks to address longstanding areas of uncertainty by providing more structured guidance on how key GDPR principles apply in a research context. The Guidelines are intended to help organisations make greater use of data for research purposes while maintaining a high standard of data protection.

The draft Guidelines are particularly noteworthy for organisations engaged in scientific research, as they clarify the scope and application of the GDPR’s research-specific flexibilities. In particular, the main takeaways are:

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