Article 9 Web-Scraping Governance Checklist

 A practical companion to Web Scraping & Article 9 GDPR: Is Sensitive Data Yours for the Taking?

This checklist translates the EDPB’s draft Guidelines 03/2026 into practical governance actions and evidence requirements across six stages: scoping, sourcing and collection, post-collection controls, training and evaluation, deployment, and the AI supply chain. It also includes the EDPB’s four-condition test, illustrative examples, warning signs that processing is no longer merely incidental, and links to the primary legal sources.