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Positionspapier EDPB Guidelines Data protection by Design & by Default

Bitkom welcomes the opportunity to comment on the European Data Protection Board’s (EDPB) draft Guidelines on Data protection by Design and by Default. We believe that more cooperation and exchange between data protection authorities and practitioners is needed to translate the legal text of the GDPR into practice and reduce legal uncertainty. We therefore appreciate that the EDPB published the draft Guidelines to provide clarity for scope and interpretation of Article 25 GDPR. We welcome that the Guideline show that the Principles of Data Protection by Design and by Default embody, above all, the principles of Art. 5 and 6 GDPR and the risk based approach.
 

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