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eIDAS 2.0 and GDPR

eIDAS 2.0 and GDPR: practical guide on eIDAS 2.0, trust services and compliance, for IT, privacy and leadership.

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Identity data is personal data

Wallet attributes, national identifiers, certificate metadata and biometrics fall under GDPR. eIDAS sets technical frames; GDPR requires legal basis, minimisation, DPIA and data subject rights.

Processing register

Add trust services and wallet integrations to your processing record: purpose, basis, retention, subprocessors (QTSP), transfers outside EEA. ISO 27701 helps link privacy and security.

EUDI wallet design targets minimal data sharing. Document how your service requests attributes, not ‘fetch everything’ because the API allows it.

Checklist

  • Inventory eID, QES and QTSP use
  • Map vendors and trust list status
  • Link to ISMS, GDPR and risk register
  • Plan DPIA where wallet or identity data
  • Test fallback and incident scenarios

Practical next step

For eIDAS 2.0 GDPR, ISO Ready links identity, trust and security measures in one ISMS, with actions, evidence and vendors toward audit. Run the readiness scan on iso-ready.nl.

More on eIDAS 2.0

Key takeaways

  • Inventory trust services and wallet use before major projects.
  • Link eIDAS to ISMS, GDPR and vendor register, one trail.
  • Test fallback and logging; QES outage is a business continuity scenario.

Frequently asked questions

When does eIDAS 2.0 apply to eIDAS 2.0 and GDPR?
When you offer or consume digital identity, wallet attributes, QES or qualified trust services in the EU, alongside national implementation timelines.
Does eIDAS replace ISO 27001?
No. eIDAS regulates trust services; ISO 27001 helps the ISMS and evidence for security controls around PKI, logging and vendors.
How does this relate to national eID schemes?
National schemes remain; eIDAS 2.0 adds the EUDI wallet and EU-wide interoperability. Plan transition and fallback.
What role does GDPR play?
Identity and attribute data are personal data. DPIA, records and minimisation remain leading.
How do we start with eIDAS 2.0 and GDPR?
Inventory current trust services, map vendors and link to ISMS and privacy records before rolling out new wallet or QES processes.

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