The Alliance for Responsible Data Collection (ARDC) submitted comments on the European Data Protection Board’s proposed Guidelines 03/2026 on web scraping in the context of generative AI.
The submission supports safeguards for personal data, including clear collection criteria, transparency, and respect for individuals’ rights. ARDC also urges the EDPB to distinguish those protections from website operators’ preferences about automated access to public information. A robots.txt file or CAPTCHA does not, on its own, establish an individual’s expectations under the GDPR.