GDPR Recital 159: scientific research is read broadly (Regulation (EU) 2016/679, recital 159)
The recital names technological development and privately funded research, which is why some argue that AI model training can count as research. No regulator has said that a licence to a commercial buyer qualifies, so a holder should not rely on this alone.
Dated 18 Oct 2026Source checked 18 Oct 2026Basis: primary text
In the source's own words
“For the purposes of this Regulation, the processing of personal data for scientific research purposes should be interpreted in a broad manner including for example technological development and demonstration, fundamental research, applied research and privately funded research.”
Where it was read
Also read from the same source
- GDPR Article 5(1)(b): purpose limitation (Regulation (EU) 2016/679, Art 5(1)(b))
- GDPR Article 6(1)(f): legitimate interests as a lawful basis (Regulation (EU) 2016/679, Art 6(1)(f))
- GDPR Article 6(4): compatibility test for a new purpose (Regulation (EU) 2016/679, Art 6(4))
- GDPR Recital 50: further processing and the legal basis (Regulation (EU) 2016/679, recital 50)
- GDPR Article 9(1): special categories of personal data (Regulation (EU) 2016/679, Art 9(1))
- GDPR Article 13(3): telling people before a new purpose (Regulation (EU) 2016/679, Art 13(3))
Figures it counts in
It is shown on its own, not counted into a figure.
Cited in this guide