There is a contradiction in the position not to say anything about the commercial arrangements between actors and the insistence that atoms must be received free of charge. The requirement doesn't help with any aspect of provacy.

Aside to the issue about conflicting principles, there is a practical issue created by GDPR. Data Engines cannot charge for access to all personal data and if they can’t charge to receive them, then there will always be a loophole. In practice, some Data Engines will be able to build their terms of service to give free uploads but, I think, we should allow this as a point of differentiation.