Personal data in EU digital wallets in light of recent developments in EU data protection law

Bilgesu Sumer

Keywords: GDPR, Digital Wallets, SRB, Personal data, controller, digital omnibus

TL;DR: This paper discusses the proposed changes to the definition of personal data under Digital Omnibus Proposal (DOP) in the context of EU Digital Wallet ecosystem.

Abstract:

This paper discusses the proposed changes to the definition of personal data under the GDPR by the Digital
Omnibus Proposal (DOP). It applies this new interpretation to the EU Digital Wallet ecosystem to assess whether
the DOP would achieve its promises, namely bringing simplification and legal clarity. It essentially argues that
the proposed changes might not bring clarity, and on the contrary, risk compounding the existing uncertainties
and legal risks.

Submission Number: 14