Data Strategy Briefing — June 28, 2024
The European Commission issued common consent form templates for data altruism under the Data Governance Act, forcing data trusts and civic data collaboratives to align intake processes before 2025 registration audits begin.
Executive briefing: Commission Implementing Regulation (EU) 2024/1860, published on 28 June 2024, sets harmonised consent form templates for organisations seeking data altruism status under the Data Governance Act. Data intermediaries and non-profits that collect personal and business data for altruistic purposes must update onboarding journeys, retention schedules, and withdrawal mechanisms so they mirror the mandatory fields and language prescribed by the regulation.
Key governance checkpoints
- Template adoption. Replace legacy consent artefacts with the EU template, ensuring translations preserve prescribed statements about voluntary participation, processing purposes, and rights to withdraw.
- Data minimisation. Align requested attributes with the regulation's requirement to gather only what is necessary for the declared altruistic purposes, documenting justifications for any optional fields.
- Withdrawal workflows. Implement revocation channels that honour Article 21 DGA obligations, including evidencing destruction or anonymisation of previously shared datasets.
Operational priorities
- Registration readiness. Prepare supporting documentation for competent authorities reviewing data altruism status, highlighting how consent records map to the new templates.
- Third-party onboarding. Update agreements with partner research institutions to ensure downstream processing respects the consent scope captured via the EU forms.
- Audit trails. Enhance logging so organisations can prove when consent was captured, refreshed, or withdrawn across multi-channel collection points.
Enablement moves
- Train frontline staff and volunteers on the updated script requirements embedded in the Commission's template.
- Review privacy notices and data subject rights workflows to ensure consistency with the consent statements.
Sources
Zeph Tech updates data altruism programmes with compliant consent flows, withdrawal evidence, and authority-ready documentation.