The most productive place to start is a product-data inventory and a practical drill on a data request: who holds the data your connected products and their related services generate, where, and in what format — and if a user asked today for access to their own data, or for it to be passed to a third party, how would that actually run? The gaps usually become visible in that drill.
The EU Data Act gives users of connected products rights of access to and portability of the data they generate, and puts obligations on the data holder to provide access, to offer fair contractual terms and to share in defined circumstances. The first steps are establishing scope, building the data inventory, reviewing the B2B and B2C contract terms, and drawing up the technical plan for the access mechanism. Where personal data is also involved, compliance with the Personal Data Protection Law (No. 6698) has to be designed at the same time.
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