EDPB Opinion 28/2024, para 102: a waiting period and an unconditional opt-out (EDPB Opinion 28/2024, adopted 17 December 2024, para 102(a)-(b))
The EDPB lists a delay between announcing and using the data, and an opt-out that needs no reasons. A holder can build both into its notice period before a lot is delivered.
Dated 18 Oct 2026Source checked 18 Oct 2026Basis: primary text
In the source's own words
“Observing a reasonable period of time between the collection of a training dataset and its use. This additional safeguard may enable data subjects to exercise their rights during this period, with the reasonable period of time being assessed depending on the circumstances of each case. ... Proposing an unconditional 'opt-out' from the outset, for instance by providing a discretionary right to object to data subjects before the processing takes place”
Where it was read
Also read from the same source
- EDPB Opinion 28/2024, para 66: the legitimate interest test must be assessed and documented (EDPB Opinion 28/2024, adopted 17 December 2024, para 66)
- EDPB Opinion 28/2024, para 92: a privacy notice is not enough to create expectations (EDPB Opinion 28/2024, adopted 17 December 2024, para 92)
- EDPB Opinion 28/2024, para 101: masking and substituting personal data (EDPB Opinion 28/2024, adopted 17 December 2024, para 101(c))
- EDPB Opinion 28/2024, para 114: corrective measures can reach the whole dataset (EDPB Opinion 28/2024, adopted 17 December 2024, para 114)
- EDPB Opinion 28/2024, para 129: the next party must check where the data came from (EDPB Opinion 28/2024, adopted 17 December 2024, para 129)
- EDPB Opinion 28/2024, para 134: a claim of anonymity must be shown (EDPB Opinion 28/2024, adopted 17 December 2024, para 134)
Figures it counts in
It is shown on its own, not counted into a figure.
Cited in this guide