Rina Steenkamp - Privacy and technology

My annotated General Data Protection Regulation

[Additional information]


January 2012

Amendments and deletions

Amendments and deletions in the October 2013 version are indicated as follows:

[Source: October 2013]


Allocation of recitals to articles

Prior to the LIBE vote, EDRi published a leaked version of the Regulation which included recitals with the articles. (There is a more official document that also contains an allocation of recitals to articles, but I didn't yet have that at the time.)

My first step was to plot the allocation of recitals to articles from the leaked documents in a table with the recitals on one axis and the chapters and sections of the Regulation on the other. This gave me the general 'flow' of the recitals in relation to the remainder of the Regulation. Based on this general 'flow', I filled in the gaps so that every recital was allocated to an article. I then made a couple of corrections where, based on the text, the allocation seemed obviously wrong. In the few cases that recitals applied to more than one article, I allocated them to the section or chapter that the relevant articles were in.

In most cases, there was a fairly obvious connection between the recitals and the articles. The exception were recitals 136-138, which weren't in the EDRi files and didn't seem clearly connected to anything in the Regulation. For want of a better solution, I've included them under Article 91.

[Source: Recitals]