Video Games Europe Response to the Public Consultation on the EDPB’s DPIA Template

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.