Navigating the leaked GDPR and Data Act Omnibus document

GDPR & Data Act Digital Omnibus: this is *NOT* the final version we expect the Commission to publish in two weeks (already made public by some outlets such as Contexte). But this way anyone keen on reading in more detail the points I summarised and commented in my previous post on the GDPR aspects (see https://lnkd.in/e-2DEeFE ) can do so without looking too far.

Some key pagination tidbits (based on page number of the PDF, not the pagination at the bottom – the document includes 18 pages first of explanatory memorandum before pagination starts again):
– Data Act related recitals: pages 21-26
– GDPR- & ePrivacy-related recitals: pages 26-34
– Data Act changes: pages 35-69 (=> notably integrating within the Data Act various provisions from the Data Governance Act, Open Data Directive and Free Flow of Non-personal Data Regulation)
– GDPR changes: pages 71-77 (see my comments here: https://lnkd.in/e-2DEeFE )
– Single-entry point incident reporting (NIS2 amendments, plus eIDAS & DORA changes): pages 78-81
– Repeal of Data Governance Act, Open Data Directive and Free Flow of Non-personal Data Regulation: page 82 (see also correlation tables in pages 84-89)

As an added bonus, the section on AI model training – Article 88c – should in my view be read in conjunction with the factual findings from the recent Getty Images v Stability AI judgment – see https://lnkd.in/eKtgkCcs

Final note: I’m not convinced that those who originated the leak were pro-business – in fact, a noyb-related post reveals quite literally that noyb.eu received it a full day before journalists and that noyb.eu were being called for ten days before that. So the leak to journalists (several of whom published it a day before this post) doesn’t seem to have been a leak by any “pro-industry” camp.

EDIT: thoughts on the actual proposal: https://lnkd.in/eXRWUfvA “