Data Strategy Briefing — December 10, 2025
As EU authorities exercise Data Act Chapter V powers for the first winter season, data holders must validate emergency request workflows, refusal criteria, and evidence capture to withstand scrutiny.
Executive briefing: With the Data Act in force, public-sector bodies can request access to privately held data for exceptional needs (disasters, public emergencies) under Chapter V. December 2025 marks the first winter season where energy, transport, and health operators should expect cross-border requests and must respond without undue delay while protecting trade secrets and confidential information.
Key governance checkpoints
- Request intake. Stand up dedicated channels to authenticate competent authorities, log legal bases, and capture scope before data is released.
- Trade secret safeguards. Document masking techniques, confidentiality agreements, and proportionality assessments supporting any field redactions.
- Exit controls. Track duration limits and deletion confirmations once emergency circumstances end.
Operational priorities
- Scenario planning. Run tabletop exercises covering energy shortages, public health incidents, and climate-driven disruptions that may trigger Chapter V requests.
- Cross-border coordination. Align subsidiaries across Member States on consistent response playbooks and reporting to national authorities.
- Evidence readiness. Maintain logs, correspondence, and legal analyses to defend refusals or partial disclosures.
Enablement moves
- Integrate Chapter V metrics into crisis management dashboards for executive oversight.
- Update privacy notices and customer communications to explain lawful emergency disclosures.
Sources
Zeph Tech equips operators with Chapter V request playbooks, masking strategies, and regulator-ready evidence.