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GDPR

Regulation (EU) 2016/679 (General Data Protection Regulation)

Foundational EU data protection law with direct AI enforcement precedent. Article 22 restricts automated decision-making; Article 9 classifies mental health data as special category requiring explicit consent; Article 8 sets children's consent thresholds (13-16 by member state).

Jurisdiction

European Union

EU

Enacted

Apr 27, 2016

Effective

May 25, 2018

Enforcement

EU/EEA Data Protection Authorities + EDPB coordination

Who Must Comply

This law applies to:

  • Controllers/processors handling EU personal data
  • Non-EU entities processing EU residents' data (extraterritorial)

Who bears obligations:

Safety Provisions

  • Article 22: Right not to be subject to decisions based solely on automated processing with legal/significant effects
  • Article 9: Mental health data is "special category" requiring explicit consent
  • Article 8: Children's consent threshold 13-16 years (varies by member state); parental consent below
  • Articles 13/14: Transparency about automated decision-making logic, significance, consequences
  • Article 35: DPIA required for high-risk processing (health data, systematic monitoring)
  • Data protection by design and by default
  • Data subject rights (access, deletion, objection, portability)
  • Security + 72-hour breach notification

Enforcement

Enforced by

EU/EEA Data Protection Authorities + EDPB coordination

Penalties

€20M or 4% revenue (whichever higher)

Max fine: €20,000,000
Revenue %: 4%

Up to €20M or 4% global annual turnover (whichever higher).

Private Right of Action

Individuals can sue directly without waiting for regulatory action. This significantly increases liability exposure.

Quick Facts

Binding
Yes
Mental Health Focus
Yes
Child Safety Focus
Yes
Algorithmic Scope
Yes
Private Action
Yes

Why It Matters

The Replika enforcement (€5M, May 2025) establishes companion AI processes special category health data. Italian DPA found "confidant, therapist, romantic partner" positioning requires enhanced protections. This reasoning applies EU-wide.

Recent Developments

Italy Garante fined OpenAI €15M (Dec 20, 2024). Garante fined Replika €5M (decision Apr 10, 2025; announced May 19, 2025)—among the first major companion AI enforcement actions. EDPB Opinion 28/2024 addresses AI model training.

What You Need to Comply

You need: lawful basis (explicit consent for mental health data under Art. 9); DPIA for high-risk features; data minimization + retention deletion; user rights workflows; Art. 22 posture for significant automated decisions; age verification/parental consent for children.

NOPE can help

Cite This

APA

European Union. (2016). Regulation (EU) 2016/679 (General Data Protection Regulation). Retrieved from https://nope.net/regs/eu-gdpr

BibTeX

@misc{eu_gdpr,
  title = {Regulation (EU) 2016/679 (General Data Protection Regulation)},
  author = {European Union},
  year = {2016},
  url = {https://nope.net/regs/eu-gdpr}
}