- Official EDPB guidance on valid consent mechanics.
References and citations
- Primary source for Articles 5 to 7 and related transparency duties.
- Useful official guidance for recording Article 6 legal basis in accountability records.
Lawful basis should be mapped per purpose, system behaviour, and notice, not chosen once and forgotten.
Consent is only one Article 6 route, and where it is used the proof and withdrawal model must be as strong as the collection flow.
Structured answer sets in this page tree.
Cited legal and guidance references.
The most common lawful-basis failure is not choosing the wrong label once. It is letting the purpose, the actual system behaviour, the notice, and the evidence drift apart over time. A workable GDPR model starts with a purpose register, assigns the lawful basis for each purpose, records why that basis is appropriate, and forces changes through the same review path that governs product and marketing changes. Where consent is used, you also need a proof, withdrawal, and downstream-enforcement model.
Do not assign lawful basis by product or by team. Assign it by concrete processing purpose.
That is the only way to keep the register aligned with notices, retention, and rights handling.
Legitimate interests is often operationally useful, but it needs a real balancing assessment and a clear objection path.
Without that record, the basis tends to collapse under scrutiny.
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