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The Europol Regulation and Purpose Limitation:

From the ‘Silo-Based Approach’ to … What Exactly?

Fanny Coudert


The Europol Regulation entered into force on the 1 May 2017. The instrument has however received little attention and the content was hardly debated. Yet, it brings forth a major change in terms of data protection: the principle of purpose limitation is not implemented anymore through the so-called ‘silo-based approach’. The focus of the Regulation is not on databases but on data processing operations. This article reviews the impact of this shift, in particular as purpose limitation is restated as fundamental principle in the field of law enforcement cooperation, both because of the opacity of the personal data processing operations and their significant impact on the lives and freedoms of individuals. To that end, it first describes the context and content of the reform before highlighting the limits of this approach. It finally formulates some recommendations for the implementation of purpose limitation in this new context.

Fanny Coudert, Researcher at the KU Leuven Center for IT and IP Law (CiTiP)-iMEC. For correspondence: <>. The author would like to thank Prof Peggy Valcke, Prof Frank Verbruggen and Prof Els Kindt for their input and critical views on the content of this research. The research reported in this article has received funding from the European Union 7th Framework Programme FP7/2007-2013, through the VALCRI project under grant agreement no FP7-IP-608142, awarded to BL William Wong, Middlesex University London, and Partners.


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