Response to the EDPB Guidelines 01/2024 on the Processing of Personal Data Based on Article 6(1)(f) GDPR

Video Games Europe provides a formal industry response to the European Data Protection Board’s (EDPB) Guidelines 01/2024, which concern the processing of personal data under the legitimate interest provision of Article 6(1)(f) of the General Data Protection Regulation (GDPR). The primary purpose of this submission is to advocate for a balanced interpretation of data processing requirements that accounts for the operational realities of the video game sector while maintaining robust privacy standards.

The industry position emphasizes that legitimate interest serves as a critical legal basis for various essential functions within gaming, including fraud prevention, network security, and the delivery of personalized user experiences. By engaging with the EDPB’s regulatory framework, the organization seeks to ensure that the final guidelines do not inadvertently restrict the ability of developers and publishers to maintain secure, functional, and engaging digital environments. The response highlights the necessity of maintaining flexibility for data controllers to pursue legitimate business objectives without imposing disproportionate compliance burdens that could stifle innovation or degrade service quality.

This policy intervention reflects the broader regulatory landscape in the European Union, where the video game industry is increasingly subject to rigorous oversight regarding data privacy, consumer protection, and the safety of minors. By participating in the consultation process, the industry aims to shape the interpretation of GDPR principles to ensure they remain compatible with the technical and commercial dynamics of modern interactive entertainment. The submission underscores a commitment to responsible data stewardship while defending the industry's reliance on legitimate interest as a foundational element of its digital infrastructure.