Mutualizzazione dei dati tra terzo settore, data protection law e digital service act

Data cooperatives have recently been introduced and regulated within the Data Governance Act (DGA, EU Reg. 868/2022), as providers of data intermediation services «intended to establish commercial relationships for the purposes of sharing of data between an indeterminate number of data subjects and data controllers, on the one hand, and data users, on the other, through technical, legal or other means (…)» (art. 2, no. 11, DGA). This is a discipline that is as innovative as it is incomplete. The work aims, on a legal level, at a systematic framework of the case in light of the multiple regulatory areas concerned and involved. In particular, we intend to refer to the Third Sector (Third Sector Code), the protection of personal data (General Data Protection Regula-tion or GDPR) and the new rules for online intermediaries (DSA). The data cooperative, in fact, presents itself as threefold: it is an entity that pursues solidarity purposes, it processes personal data and, finally, it is an intermediary for data services.