# Data protection by design and by default — GDPR — context bundle

> Focused context for a single provision, curated from overview.legal on 2026-08-22. Canonical page: https://overview.legal/laws/gdpr/art-25
> Every item cites its source. Verify against the official text (EUR-Lex / wetten.overheid.nl) before relying on it.

## Provision

### Data protection by design and by default — Data protection by design and by default

*GDPR, gdpr-art-25-en — https://overview.legal/laws/gdpr/art-25*

1. Taking into account the state of the art, the cost of implementation and the nature, scope, context and purposes of processing as well as the risks of varying likelihood and severity for rights and freedoms of natural persons posed by the processing, the controller shall, both at the time of the determination of the means for processing and at the time of the processing itself, implement appropriate technical and organisational measures, such as pseudonymisation, which are designed to implement data-protection principles, such as data minimisation, in an effective manner and to integrate the necessary safeguards into the processing in order to meet the requirements of this Regulation and protect the rights of data subjects.

2. The controller shall implement appropriate technical and organisational measures for ensuring that, by default, only personal data which are necessary for each specific purpose of the processing are processed. That obligation applies to the amount of personal data collected, the extent of their processing, the period of their storage and their accessibility. In particular, such measures shall ensure that by default personal data are not made accessible without the individual's intervention to an indefinite number of natural persons.

3. An approved certification mechanism pursuant to Article 42 may be used as an element to demonstrate compliance with the requirements set out in paragraphs 1 and 2 of this Article.

## Related recitals

### Recital 106 — commission monitoring of adequacy decisions

The Commission should monitor the functioning of decisions on the level of protection in a third country, a territory or specified sector within a third country, or an international organisation, and monitor the functioning of decisions adopted on the basis of Article 25(6) or Article 26(4) of Directive 95/46/EC. In its adequacy decisions, the Commission should provide for a periodic review mechanism of their functioning. That periodic review should be conducted in consultation with the third country or international organisation in question and take into account all relevant developments in the third country or international organisation. For the purposes of monitoring and of carrying out the periodic reviews, the Commission should take into consideration the views and findings of the European Parliament and of the Council as well as of other relevant bodies and sources. The Commission should evaluate, within a reasonable time, the functioning of the latter decisions and report any relevant findings to the Committee within the meaning of Regulation (EU) No 182/2011 of the European Parliament and of the Council (12) as established under this Regulation, to the European Parliament and to the Council.

## Enforcement

222 decision(s) on record cite Article 25, totalling approximately €924,042,595 in fines (median €50,000).

Top fines:
- **Meta Platforms, Inc.: Non-compliance with general data processing principles** (IRELAND, €405,000,000) — https://overview.legal/posts/47488
- **TikTok Limited: Non-compliance with general data processing principles** (IRELAND, €345,000,000) — https://overview.legal/posts/48147
- **Wind Tre S.p.A.: Insufficient legal basis for data processing** (ITALY, €16,700,000) — https://overview.legal/posts/46451
- **OpenAI OpCo LLC: Non-compliance with general data processing principles** (ITALY, €15,000,000) — https://overview.legal/posts/48612
- **Vodafone Italia S.p.A.: Non-compliance with general data processing principles** (ITALY, €12,251,601) — https://overview.legal/posts/46553

## Guidance

### Guidelines on processing of personal data through blockchain technologies

*EDPB — https://overview.legal/posts/125668*

Guidelines 02/2025 on processing of personal data through blockchain technologies Version 2.0 Adopted on 07 July 2026 1 | Adopted Version history Version Date Adoption information version 1.1 08 April 2025 adoption of the guidelines before public consultation version 2.0 07 July 2026 adoption of the guidelines after public consultation 3 | Adopted 4 | Adopted The European Data Protection Board Having regard to Article 70 (1)(e) of the Regulation 2016/679/EU of the European Parliament and of the…

### Opinion 15/2026 on the Europrivacy certification criteria regarding their approval by the Board as European Data Protection Seal to be used as tool for transfers pursuant to Articles 42 and 46 GDPR

*EDPB — https://overview.legal/posts/125681*

Opinion 15 / 2026 on the Europrivacy certification criteria regarding their approval by the Board as European Data Protection Seal to be used as tool for transfers pursuant to Articles 42 and 46 GDPR Adopted on 15 April 2026 1 | Adopted 2 | Adopted The European Data Protection Board Having regard to Article 63, Article 64(2), Article 42 and Article 46 of the Regulation 2016/679/EU of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to…

### Opinion 14/2026 on the Europrivacy certification criteria regarding their approval by the Board as European Data Protection Seal pursuant to Article 42.5 GDPR

*EDPB — https://overview.legal/posts/125682*

Opinion 14 / 2026 on the Europrivacy certification criteria regarding their approval by the Board as European Data Protection Seal pursuant to Article 42.5 GDPR Adopted on 15 April 2026 1 | Adopted 2 | Adopted The European Data Protection Board Having regard to Article 63, Article 64 (2) and Article 42 of the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free…

### EDPB Annual Report 2025

*EDPB — https://overview.legal/posts/125683*

Clarity in action: Supporting stakeholders through guidance and dialogue Annual Report 2025 Foreword 3 Highlights 4 1. The EDPB Secretariat 6 1.1 Mission And Activities 8 2. European Data Protection Board – Activities in 2025 12 2.1 Bridging Fundamental Rights and Digital Innovation Through GDPR Compliance 12 2.1.1 Helsinki high-level meeting: enhanced clarity, support and engagement 12 2.1.2 Regulation on procedural rules and Omnibus regulation on the record of processing 14 2.1.3 Cross…

### Report on stakeholder event on processing of personal data to target or deliver political advertisements

*EDPB — https://overview.legal/posts/125684*

Report on stakeholder event on processing of personal data to target or deliver political advertisements 27 March 2026 1. Background The EDPB organised an online stakeholder event on 27 March 2026 to collect stakeholders’ input on processing of personal data to target or deliver political advertisements. The objective was to engage with stakeholders at an early stage of drafting the EDPB Guidelines on the processing of personal data to target or deliver political advertisements (Chapter III of…

## Related topics

- **Accountability** — https://overview.legal/topics/accountability
  ## Legal Framework
- **Privacy by Design** — https://overview.legal/topics/privacy-by-design
  ## Legal Framework
- **Privacy by Default** — https://overview.legal/topics/privacy-by-default
  ## Legal Framework

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Generated by overview.legal · https://overview.legal/laws/gdpr/art-25 · 2026-08-22
