Digital Omnibus proposal: what it means for GDPR teams

TL;DR: The Digital Omnibus proposal could narrow what counts as personal data, consolidate breach reporting, expand legitimate-interest processing for AI, and simplify consent and DSAR handling, according to Osano, while leaving the GDPR as the anchor for broader privacy change. For practitioners, the real issue is not whether the proposal passes unchanged, but how quickly governance models would need to adapt if EU privacy obligations become more conditional and less duplicative.

Editorial analysis by NHI Mgmt Group, based on content published by Osano: “Top 10 EU Data Privacy Changes in the Digital Omnibus Proposal”.

Key questions

Q: How should organisations respond if GDPR scope is narrowed for some data types?

A: They should not treat narrower scope as permission to weaken governance.

Q: Why do simplified breach reporting rules still require strong incident governance?

A: Because simplification changes the reporting path, not the need for evidence.

Q: What breaks when consent management is treated only as a banner problem?

A: Teams miss the operational requirement to honour consent state across browsers, apps, and fallback journeys.

Practitioner guidance

• Reclassify personal-data inventories Map where pseudonymised or minimally identifiable data is currently treated as personal data and document the re-identification assumptions that justify each classification.
• Redesign breach notification workflows Build one incident path that can support internal triage, regulatory reporting, and individual notification decisions without duplicating evidence collection across regimes.
• Tighten consent signal handling Verify that websites and apps can accept browser-level consent signals and still fall back cleanly to banner-based consent where needed.

Bottom line: The Digital Omnibus proposal would reduce some compliance friction, but it shifts governance pressure toward scope decisions, evidence, and exception handling.

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