Video Games Europe formally opposes the EDPB’s draft DPIA template, arguing it risks transforming risk-based assessments into overly prescriptive, exhaustive procedural checklists.
The association contends that the current draft exceeds the scope of Article 35 of the GDPR, which mandates that DPIAs remain proportionate and risk-focused rather than operational manuals.
Industry stakeholders fear that the proposed level of technical and contractual detail will impose unnecessary administrative burdens on game developers and publishers.
Video Games Europe warns that the current template design could stifle innovation within the European gaming sector by creating rigid compliance requirements.
The organization advocates for a balanced regulatory approach that preserves the flexibility of DPIAs while still ensuring full adherence to GDPR principles.
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