The Battle for Data Availability under EU Digital Regulation: Anonymisation, Reuse, and the Future of Personal Data
European digital regulation is entering a new phase. While the first generation of data law focused primarily on fundamental rights, accountability, and constraints on processing, newer legislative initiatives increasingly seek to make data more available for innovation, competition, public-sector efficiency, particularly through artificial intelligence development.
In the EU, this trend can be observed across the Digital Markets Act (DMA), the Data Governance Act (DGA), the Data Act, the proposed European Health Data Space (EHDS), and the broader EU AI regulatory ecosystem. These initiatives rely, directly or indirectly, on greater data access, reuse, interoperability, and lawful circulation.
At the same time, this policy turn raises significant legal and normative questions. Greater availability often depends on mechanisms such as anonymisation, pseudonymisation, privacy-enhancing technologies, secure processing environments, and narrower practical understandings of what constitutes personal data.
This call for papers seeks to critically evaluate the emerging data availability agendas and examine whether current reforms strike an appropriate balance between competitiveness, innovation, and fundamental rights protection.
Contributors are invited to assess the role of anonymisation, data reuse, access mandates, and evolving definitions of personal data across European digital rulebooks. Authors are also encouraged to make concrete recommendations for improving coherence, effectiveness, and legitimacy of key regulatory chapters.
Areas of Interest
Authors are invited to submit opinion pieces/papers addressing the following themes and questions:
- The Rise of Data Availability
- Is EU digital regulation shifting from data minimisation toward data mobilisation?
- Which instruments most clearly embody a new data availability logic?
- Anonymisation and the Scope of Personal Data
- Can anonymisation still function as a reliable legal boundary in an era of advanced AI practices and re-identification techniques?
- Is EU law indirectly narrowing the practical concept of personal data?
- Reuse of Sensitive and High-Value Data
- How should the law approach secondary use of health, mobility, financial, or behavioural data?
- Can sensitive data be safely reused through technical or governance safeguards?
- Data Access as Competition and Innovation Tool
- Are DMA and competition-law access mandates likely to increase market contestability?
- Do data-sharing obligations risk entrenching incumbents who remain infrastructure gatekeepers? Can interoperability and portability substitute for structural remedies?
- AI Governance and Dataset Availability
- Can the AI Act coexist with restrictive interpretations of data access?
- How should privacy and data protection rights be balanced against the demand for large-scale datasets?
- Institutional and Constitutional Questions
- Which authorities should arbitrate tensions between privacy and data access: DPAs, competition authorities, sectoral regulators, or courts?
- Is Europe developing a coherent constitutional model for data circulation?
Submission Guidelines
Submissions should offer robust analytical insights supported by empirical evidence, including case law, regulatory decisions, technical analysis, or theoretical frameworks.
We encourage interdisciplinary approaches and welcome contributions from legal scholars, economists, technologists, political scientists, data scientists, and policymakers.
An abstract of 500 words should be sent by 31 July 2026 to Sophie (Sophie.stalla-bourdillon [at] vub.be).
Authors will be invited to participate to a workshop to present their work on 25 September 2026. Notification of invitation to the workshop will be received by 15 August.
Authors will be invited to submit their output (opinion piece, comment, full research paper) to the Computer Law and Security Review by 30 October 2026.
Deadlines
- Workshop Provisional Date: 25 September 2026
- Full Paper Submission: 30 October 2026
- Notification of Acceptance: 20 December 2026