ArticleVideo Games Europe
Video Games Europe Response to the Public Consultation on the EDPB’s DPIA Template
8 Jun 20261 pages~1 min full read
Key insights
6 slides
The response
Video Games Europe formally responds to the EDPB's public consultation.
The association submitted a formal response to the European Data Protection Board's public consultation on its draft DPIA template. The response expresses apprehensions about the current wording.
The regulatory scope
Article 35 of the GDPR requires proportionate and risk-based DPIAs.
The association argues that the current draft exceeds the scope mandated by Article 35 of the General Data Protection Regulation. Article 35 requires DPIAs to be proportionate and risk-based rather than exhaustive procedural checklists.
The risk
The draft risks transforming risk-based assessments into exhaustive procedural checklists.
Video Games Europe formally opposes the EDPB's draft DPIA template. The association argues it risks transforming risk-based assessments into overly prescriptive, exhaustive procedural checklists.
The burden
Stakeholders fear the proposed detail will impose unnecessary administrative burdens.
Industry stakeholders fear that the proposed level of technical and contractual detail will impose unnecessary administrative burdens on game developers and publishers. The response underscores a broader concern that overly detailed templates may stifle innovation.
The innovation warning
The current template design could stifle innovation within the European gaming sector.
Video Games Europe warns that the current template design could stifle innovation within the European gaming sector by creating rigid compliance requirements. The association argues that overly detailed templates may impose unnecessary administrative burdens.
The recommendation
Video Games Europe advocates for a balanced regulatory approach.
The organization advocates for a balanced regulatory approach that preserves the flexibility of DPIAs while still ensuring full adherence to GDPR principles. The position calls for maintaining regulatory intent without converting DPIAs into rigid operational manuals.
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Summary
Video Games Europe has formally responded to the European Data Protection Board’s public consultation on its draft DPIA template, expressing apprehensions that the current wording could transform data protection impact assessments into overly prescriptive, technical, contractual or operational catalogues. The association argues that such a shift would exceed the scope mandated by Article 35 of the General Data Protection Regulation, which requires DPIAs to be proportionate and risk‑based rather than exhaustive procedural checklists. By highlighting this potential misalignment, Video Games Europe seeks to preserve the flexibility and practicality of DPIAs for industry stakeholders while ensuring compliance with GDPR principles. The response underscores a broader concern that overly detailed templates may stifle innovation and impose unnecessary administrative burdens on game developers, publishers and related service providers across Europe. The association’s position calls for a balanced approach that maintains the regulatory intent of DPIAs without converting them into rigid operational manuals.
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