On April 15, 2026, the European Data Protection Board (“EDPB”) published its long-awaited draft Guidelines 1/2026 on the processing of personal data for scientific research purposes (the “Guidelines”), marking the most comprehensive regulatory statement to date on how the GDPR applies to scientific research activities.
For organizations in the life sciences sector, the Guidelines address long-standing areas of uncertainty — particularly around secondary use of data, broad consent, and transparency obligations — while signaling a clear shift toward stricter expectations on governance, purpose limitation, and accountability. The EDPB’s objective is clear: to promote a more consistent and workable framework across the EU, while maintaining robust safeguards. The public consultation closed on 25 June 2026, and the Guidelines remain in draft pending adoption of a final version.
