Interactive Software Federation of Europe

Position Papers

ISFE position on the proposed Data Protection Regulation

In 2012, the Commission proposed a major reform of the EU legal framework on the protection of personal data. The new proposals are to strengthen individual rights and tackle the challenges of globalisation and new technologies. ISFE welcomes this initiative to modernise the framework and to try and establish greater harmonisation of various national frameworks. At the same time we have concerns that the wide-ranging nature and scope of the Regulation and the inflexibility and lack of definition of a number of key concepts defined therein may make implementation more difficult and enhance legal uncertainty as well as increase the cost of compliance for companies of all sizes. More details on the position of ISFE can be found in the below document.

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European Commission Consultation on Opening Up Education

The European Commission has held a consultation to explore the perceived need - mainly but not exclusively among education and training stakeholders – for EU action to promote the use of Open Educational Resources (OER) and of ICT in education.

New technologies, in particular the internet, together with globalisation and the emergence of new education providers, are radically changing the way people learn and teach. Open access to education resources offers an unprecedented opportunity to enhance both excellence and equity in education. The EU aims to help both individual learners and education and training institutions in Member States to benefit from these opportunities and to increase their contribution to society.

The Commission will present a Communication on Rethinking Skills aiming to increase the quantity, quality and relevance of skills supply for higher economic and social outcomes. This will, among other actions, announce a new EU Initiative on "Opening up Education": a proposal to exploit the potential contribution of ICTs and Open Educational Resources (OER) to education and skills development. This new EU initiative will be the topic of a subsequent Communication in mid-2013.

ISFE participated in the discussion by offering some additional comments that can be found in this document:

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ISFE Response to Code for Effective Open Voluntarism

The European Commission has launched a public consultation seeking input from citizens, organisations, public authorities and all stakeholders potentially engaged or interested in self- and co-regulation and other multistakeholder voluntary actions in the EU on how best to codify a set of design principles for achieving objectives through a multi-stakeholder process. The aim of this code is to improve the framework for achieving EU policy objectives.

The consultation covers the following three points:
1) to gather comments on the draft Code
2) to develop a cross-EU and multi-sectoral Network of Excellence, including the sharing of useful reference material and best practices
3) to gather knowledge, ideas and opinions about how to ensure that voluntarism receives its appropriate share of attention in the policy-making toolbox.
Contributions could be made until September 30th 2012 through the Online Interactive Policy-making questionnaire. Additionally, a public meeting on the code was held on 10 September in Brussels. ISFE contributed with a number of observations and comments that can be found in the document below.

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High-Level Statement of the Industry Coalition for Data Protection (ICDP)

ISFE has joined a coalition of leading business organisations in Europe with which we share the view that the revised Data Protection Framework must be robust, balanced, effective and future-proof and must increase legal certainty. Consumers and business will only benefit from this review if it strikes the right balance between the protection of Europeans’ fundamental right to privacy and data protection, and the promotion of innovation, competitiveness and growth in the Digital Single Market. Under the name Industry Coalition for Data Protection (ICDP) the group published a statement (available below) which includes some of their key thoughts on the new EU Data Protection Regulation.

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Legal Framework for Data Protection

The European Commission is currently in the process of reviewing the general EU legal framework on the protection of personal data. For that purpose, the Commission organised a wide stakeholders' conference on data protection in May 2009 and launched a public consultation about the future legal framework for the fundamental right to protection of personal data in the EU. The public consultation was concluded in December 2009. The submission from ISFE can be read here.

On 4 November 2010 the Commission adopted a strategic Communication on a comprehensive strategy on data protection in the European Union (COM(2010)609Press release and Memo), highlighting its main ideas and key objectives on how to revise the current rules on data protection. ISFE issued a statement in response to particular issues raised in the Commission's strategic Communication to supplement the initial submission of December 2009. That statement can be downloaded here.

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