EDPB-EDPS Joint Opinion on the Digital Green Certificate

During the 47th plenary meeting held on 30-31 March 2021 the European Data Protection Board (EDPB) and the European Data Protection Supervisor (EDPS) adopted a joint opinion on the Proposals for a Digital Green Certificate.

The Digital Green Certificate aims to facilitate the exercise of the right to free movement within the European Union during the COVID-19 pandemic by establishing a common framework for the issuance, verification and acceptance of interoperable COVID-19 vaccination, testing and recovery certificates.

With this Joint Opinion, the EDPB and the EDPS invite the co-legislators to ensure that the Digital Green Certificate is fully in line with EU personal data protection legislation. The data protection commissioners from all EU and European Economic Area countries highlight the need to mitigate the risks to fundamental rights of EU citizens and residents that may result from issuing the Digital Green Certificate, including its possible unintended secondary uses.

The EDPB and the EDPS underline that the use of the Digital Green Certificate may not, in any way, result in direct or indirect discrimination of individuals, and must be fully in line with the fundamental principles of necessity, proportionality and effectiveness. Given the nature of the measures put forward by the Proposal, the EDPB and the EDPS consider that the introduction of the Digital Green Certificate should be accompanied by a comprehensive legal framework.

The EDPB and EDPS highlight that the application of the Digital Green Certificate must be strictly limited to the current COVID-19 crisis and that access to and subsequent use of individuals’ data by EU Member States once the pandemic has ended is not permitted.

In connection with the 47th plenary session, a press statement has been published on the EDPB website, of which a Polish translation is available in the annex below:


The agenda of the 47th plenary session of the EDPB is available here:


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