CNIL, re-use of data: the research presumption and why machine learning is not 'statistical' (CNIL, 'Ensuring the lawfulness of the data processing - In case of re-use of data', 7 June 2024 (courtesy translation))
The CNIL presumes research reuse is compatible, but says training a model is not a statistical purpose just because it uses statistics. A holder cannot call a commercial training licence research on that basis alone.
Dated 18 Oct 2026Source checked 18 Oct 2026Basis: primary text
In the source's own words
“Where the reuse of the data pursues statistical or scientific research purposes, the processing is presumed to be compatible with the original purpose if it complies with the GDPR and if it is not used to make decisions regarding the data subjects. ... The use of statistical techniques of machine learning is not enough to consider that they are processing "for statistical purposes", since the purpose of processing is not to produce aggregated data for themselves.”
Where it was read
Also read from the same source
- CNIL, re-use of data: the compatibility test covers sharing with third parties (CNIL, 'Ensuring the lawfulness of the data processing - In case of re-use of data, carrying out the necessary additional tests and verifications', 7 June 2024 (courtesy translation))
- CNIL, data acquired from a third party: the supplier must check compatibility and may set the limits by licence (CNIL, 'Ensuring the lawfulness of the data processing - In case of re-use of data', 7 June 2024, section on datasets acquired from a third party)
- CNIL, re-use of data: even a compatible purpose needs a lawful basis and information to people (CNIL, 'Ensuring the lawfulness of the data processing - In case of re-use of data, carrying out the necessary additional tests and verifications', 7 June 2024 (courtesy translation))
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