Limiting Legal Basis for Data Processing Under the DMA: Considerations on Scope and Practical Consequences

This paper will take an in-depth look at open questions regarding the seeming limitation by the Digital Markets Act (DMA) of legal bases available for certain processing of personal data and whether the DMA should consequently be considered as a lex specialis to the General Data Protection Regulation.

Additionally, the paper examines ambiguities related to the scope of DMA in terms of personal data processing and lack of definitions of ‘data combination’ and ‘cross-use.’