Response to Public Consultation on the EDPB's Guidelines 01/2025 on Pseudonymisation

Video Games Europe has formally submitted its response to the European Data Protection Board (EDPB) regarding the public consultation on Guidelines 01/2025 concerning pseudonymisation. The primary objective of this submission is to represent the interests and operational realities of the European video game industry in the context of evolving data privacy standards. By engaging with the EDPB, the organization seeks to ensure that regulatory frameworks governing data protection remain practical and conducive to the continued innovation and growth of the digital gaming sector.

The submission addresses the technical and legal complexities associated with pseudonymisation, a critical process for balancing user privacy with the data-driven requirements of modern game development, such as analytics, security, and personalized player experiences. While the provided text serves as a record of the industry’s participation in the consultation process, it underscores the ongoing efforts of Video Games Europe to influence policy development at the European level. The organization advocates for clear, actionable guidance that allows game developers to maintain high standards of data protection without imposing undue regulatory burdens that could stifle technical progress.

This engagement reflects the broader strategic focus of Video Games Europe on digital policy, privacy, and consumer protection within the European Union. By participating in such consultations, the industry aims to foster a regulatory environment that supports both the protection of minors and the responsible management of player data. The submission is part of a wider series of policy interventions by the organization, which frequently provides expert feedback on European Commission initiatives, including digital fitness checks and regulatory frameworks for digital networks.