European Federation of Associations of Market Research Organisations
EFAMRO
Efamro represents the interests of market, social and opinion research in Europe.
ID: 142021393144-85
Lobbying Activity
Response to Digital Fairness Act
23 Oct 2025
Our associations are responding to the European Commissions call for evidence: Digital Fairness Act. Our associations welcome the European Commissions initiative, which aims to protect consumers from manipulative design practicescommonly referred to as dark patternsand promote fairness in digital environments. Our response seeks to: Support the Acts objectives. Clarify the implications for the research and insights sector. Ensure that legitimate research practices are not inadvertently restricted.
Read full responseResponse to Digital package – digital omnibus
14 Oct 2025
EFAMRO welcomes the European Commissions Digital Omnibus package as a vital step toward a more harmonised, competitive, and innovative European data economy. The Market Research sector sits at the intersection of data-driven innovation and ethical stewardship, generating insights that inform commercial, social, and policy decisions. Members are highly aware of the challenges posed by current and proposed data regulations, including the GDPR, AI Act, and ePrivacy Directive. Since the GDPRs implementation, members have faced significant challenges in assigning data protection responsibilities across complex data chains. There is persistent uncertainty and inconsistency in how Member States interpret key GDPR provisions, particularly around research exemptions and processing for research purposes. To support the Digital Omnibus package, EFAMRO recommends: Clearer, harmonised interpretations of data protection rules across the EU, especially for research-related exemptions and role definitions. Greater alignment between the GDPR, AI Act, and ePrivacy Directive to support ethical and legally sound research practices. Towards a Harmonised European Data Protection Framework The GDPR has set global standards but suffers from fragmented implementation, conservative regulatory interpretations, and inconsistencies with other frameworks. EFAMRO supports the Commissions efforts to simplify EU data rules and recommends clearer guidance for applying GDPR in complex market research data chains. Role attribution in data processing is often unclear. The assumption that commissioning clients are always controllers distorts the reality of research workflows. Research suppliers often determine methodology and handle data independently. EFAMRO urges a case-by-case assessment of roles based on actual data flows and responsibilities, supported by clear guidelines and international codes of conduct. Research projects involve distributed responsibilities. Agencies may act as processors or controllers depending on the activity. A one-size-fits-all approach to role attribution is inadequate. Deconstructing projects into phases allows for more accurate role assessment. EFAMRO calls for tailored guidance and collaboration with regulators to ensure legal certainty and uphold ethical standards. EFAMRO advocates for a broad interpretation of Article 89 GDPR to encompass diverse legitimate research activities. The lack of a clear definition of scientific research creates legal uncertainty. Recommendations include: Broad framing of scientific research at EU and national levels. Recognition of empirical research involving personal data, including market and social research. Support for all legitimate research forms, including commercially funded projects. EFAMRO urges the Commission to adopt a common framework for scientific research, grounded in Article 89, to support cross-border data flows and legal clarity. International codes like the ICC/ESOMAR Code can guide ethical and transparent data use. EFAMRO also urges the commission to establish clear guidelines with respect to pseudonymisation, and clarify the legal status of pseudonymised data and its treatment in complex research value chains.
Read full responseResponse to European Data Union Strategy
17 Jul 2025
EFAMRO and ESOMAR welcome the European Commissions initiative to develop a coordinated European Data Union Strategy aimed at enhancing data sharing, improving data quality, and reducing regulatory fragmentation. Representing the European and global market, opinion, and social research sector, which accounts for a reported annual turnover of 34.02 billion, our associations advocate for a data governance framework that supports ethical, transparent, and scientifically grounded research practices. We believe that the successful delivery of a harmonised European data governance framework will empower the research sector to continue delivering high-quality insights that benefit citizens, businesses, and policymakers across the globe. In response to the Commissions call for evidence, we highlight several key challenges and recommendations: Legal Clarity in the GDPR: The current lack of harmonisation and conservative interpretations across Member States has led to legal uncertainty, particularly in complex data processing chains like those frequently found in market-research use-cases. We urge the Commission to develop clearer, harmonised guidelines for determining roles and responsibilities of controllers, processors, joint controllers and third-parties. In the context of market research activities, the dichotomy of controller, joint controllers and processor is not always clear or reflective of the complexity of a data chain, resulting in legal uncertainty around liability and responsibility. A case-by-case assessment should replace the default assumption that clients commissioning a research project are always data controllers, as this oversimplifies the nuanced nature of research partnerships in which it is often the research suppliers specialised expertise to shape detailed research project proposals, with limited involvement from commissioning clients. Scientific Research Framework: We advocate for a broad and inclusive interpretation of Article 89 GDPR to encompass all legitimate forms of empirical research where personal data are processed, which is also the case for market, opinion and social research. The absence of a clear definition of scientific research has resulted in inconsistent applications and operational challenges for our sector. In light of this, we recommend a common EU framework for scientific research that reflect the diverse research purposes, finding sources and applications. Furthermore, as the EU AI Act moves toward implementation, it is essential to ensure consistency with GDPR provisions regarding exemptions for scientific and statistical data processing. Alignment between the GDPR and the ePrivacy Directive: We also call for renewed efforts to harmonise the GDPR with the outdated ePrivacy Directive, particularly in areas such as consent and audience measurement exemptions. The withdrawal of the ePrivacy Regulation in early 2025 presents an opportunity to build a coherent framework that supports responsible data use and enhances legal certainty. Recognition of Self-Regulatory Instruments: International codes of conduct, such as the ICC/ESOMAR International Code on Market, and Social Research and Data Analytics, provide robust ethical and professional standards for data processing in research. These instruments should be recognised as effective tools for interpreting legal requirements and guiding responsible data use. More detailed recommendations can be found in the attached position paper.
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