In this paper I comment upon the proposed new definition of scientific research in the GDPR. I submit that it is quite bad. A proposal is made for another definition using the ALLEA 2023 Code of Conduct on research integrity. That is sufficiently broad to encompass any kind of research, also commercial. Usually a definition in a legislative text should be neutral as to the normative consequences of the activities inherent to that definition. Those come in the legislative text itself. But as those normative elements are largely absent, general normative elements must in this case embedded in the definition. Reference should be made to adhering to applicable legislation and standards of research integrity, rather than applicable ethical norms. Though referring to the latter seems a sweet magical formula, those standards lack sufficient concreteness for ex ante or ex post accountability compared to the 2 other normative elements.  You can read it on this site (with not all the formatting correct) or download the pdf.