Will broad consent be allowed according to GDPR?
Yes, according to Preamble 33: “It is often not possible to fully identify the purpose of personal data processing for scientific research purposes at the time of data collection. Therefore, data subjects should be allowed to give their consent to certain areas of scientific research when in keeping with recognised ethical standards for scientific research. Data subjects should have the opportunity to give their consent only to certain areas of research or parts of research projects to the extent allowed by the intended purpose”.
When a broad purpose is described It is advisable to be specific in the information on the processes of research, e.g. that collaboration will take place across national borders, have commercial partners involved, include genomic analyses.
The European Data Inspection Authority (former Article 29 Working Party) will issue further guidelines, as well as the upcoming Code of Conduct.