31. Does a data holder still need to share data with a third party upon request of the user where it has granted direct access to the user?

Yes. Users also have a right under Article 5 of the Data Act to request the data holder to transfer data to a third party when the user has direct access to the data in the sense of Article 3(1). This pre-supposes that there is a data holder with data readily available to them. Article 5 is not conditional upon the type of access that the user has.