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ARTICLE · 03 DECEMBER 2025

Digital Omnibus: A Victory For Technology Or Commerciality?

Herbert Smith Freehills Kramer LLP
Herbert Smith Freehills Kramer LLP
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Herbert Smith Freehills Kramer LLP

Herbert Smith Freehills Kramer LLP

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The newly published Digital Omnibus Package from the EU Commission is perhaps surprising in the obvious influence of AI and other technologies such as biometrics.

United KingdomPrivacy
Miriam Everett
Miriam Everett
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The newly published Digital Omnibus Package from the EU Commission is perhaps surprising in the obvious influence of AI and other technologies such as biometrics. Some might argue that this results in a more commercial approach, reflecting the reality of data processing in the 21st Century. Others will likely be concerned about the possible erosion of fundamental rights and freedoms.

For those of you short on time, the TL;DR of the GDPR amendment proposals is below:

Definition of Personal Data: amendment to the definition of personal data to clarify that pseudonymised data in the hands of an entity that can't re-identify the individual is not personal data.

Abuse of DSARs: a right for entities to refuse to respond to a data subject access request where the individual is abusing the right of access for a purpose other than concern about data processing.

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