Fiche 9/54
Part I — General Introduction
Intermediate
Reviewed 2026-08-23
Compatibility of Further Purposes (Art. 6.4)
Compatibility of Further Purposes (Art. 6.4)
⚡ In 30 seconds
Where a processing for a purpose other than that for which the personal data have been collected is not based on consent or Union/Member State law, the controller must conduct a compatibility assessment under Article 6(4). If compatible, no new legal ground is required; if incompatible, a separate consent (Art. 6.1.a) or law is mandatory.
| Criteria (Art. 6.4) | Assessment Requirement |
|---|---|
| 1. Link between purposes | Relationship between initial collection purpose and planned further processing. |
| 2. Collection context | Relationship between data subjects and controller, and their reasonable expectations. |
| 3. Nature of the data | Whether sensitive data (Art. 9) or criminal data (Art. 10) are involved. |
| 4. Consequences of processing | Possible adverse legal, financial, or reputational impacts on individuals. |
| 5. Appropriate safeguards | Deployment of encryption, pseudonymisation, access silos, or differential privacy. |