# Digital Omnibus - First Legal Analysis

- Type: News
- Source: noyb - European Center for Digital Rights
- Date: 2025-11-22
- Original: https://noyb.eu/en/digital-omnibus-first-legal-analysis
- Canonical: https://overview.legal/posts/49181
- Topics: Transparency, Personal Data

## Summary

GDPR Policy This week the "Digital Omnibus" came out. noyb is right now working on an in-dept written analysis that we hope to publish the next days. As a preview, we brought together team members that worked on the various aspects of the Omnibus proposal by the European Commission in a video, to go into more details on select topics (the new personal data definition, the new research exemption, limitations on transparency rules and the new rules on access to the terminal equipment). We hope thi

## Full text

GDPR Policy This week the "Digital Omnibus" came out. noyb is right now working on an in-dept written analysis that we hope to publish the next days. As a preview, we brought together team members that worked on the various aspects of the Omnibus proposal by the European Commission in a video, to go into more details on select topics (the new personal data definition, the new research exemption, limitations on transparency rules and the new rules on access to the terminal equipment). We hope this video is useful for you! Download the full video (.mp4, 1GB)Chapters:00:00 - Intro and Overview10:05 - Scope of the Video and Useful Changes11:50 - The Narrow Personal Data Definition - Article 4(1)32:00 - The Broad Research Exemption - Articles 4(38), 5(1)(b), 13 and 8941:40 - The AI rules - Articles 9(2)(k), 9(5) and 88c56:10 - Limitation to the Right to Access - Articles 12 and 151:00:50 - "SME" Exemption from Privacy Policies - Article 131:06:45 - Access to the Terminal Equipment ("Cookie

## Cited law provisions (1)

### GDPR — gdpr-art-4-par-1-en

‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

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