There is some confusion in the GDPR regarding the interplay of specific versus broad consent. The confusion is based on the language of Recital 33 and Article 6(1)(a), the latter of which covers consent to processing non-special categories of personal data, and 9(2)(a), which covers consent to processing special categories of data. Article 6(1)(a) states that personal data may be lawfully processed if "the data subject has given consent to the processing of his or her personal data for one or more specific purposes," while Article 9(2)(a) states that special categories of personal data may be lawfully processed if "the data subject has given explicit consent to the processing of those personal data for one or more specified purposes." However, Recital 33 of the GDPR states that: "It is often not possible to fully identify the purpose of personal data processing for scientific research purposes at the time of data collection. Therefore, data subjects should be allowed to give their consent to certain areas of scientific research when in keeping with recognized ethical standards for scientific research. Data subjects should have the opportunity to give their consent only to certain areas of research or parts of research projects to the extent allowed by the intended purpose." Based on your interpretation of the GDPR text and relevant guidance, do you think it is legally acceptable under the GDPR for data subjects' consent to be obtained on a "broad basis," i.e. on a description of the "certain areas of scientific research" for which their personal data will be processed, including special categories of personal data? (Note that, as explained(https://www.hhs.gov/ohrp/sachrp-committee/recommendations/attachment-c-august-2-2017/index.html ), such "broad consent" to future research uses of personal data is explicitly permitted under U.S. federal regulations.)