9th of August 2013
European Cloud Partnership - Shared Data Area Initiative – Comments from DIGITALEUROPE
DIGITALEUROPE appreciates the opportunity to comment on the ECP initiative regarding a Schengenstyle Shared Data Area (SDA).
We welcome what looks like an important step in the right direction on an incremental pathway to
full harmonization of a free flow of data across Europe.
On one hand, this plan has to be only the beginning of a longer, more ambitious journey towards a
broader area: Indeed, the data entrusted to European business must be able to travel unfettered
around the world, perhaps along the same gradual template that would have the US and Japan
invited to sign up to the SDA, for instance as part of trade agreements.
On the other hand, the plan as we understand it today is already very ambitious and exposed to
several challenges. Arguably, and as illustrated with the Schengen area, there is a real risk that
instead of achieving the key goal of enhanced harmonization, the implementation of this initiative
should result in the emergence of patches of different harmonized “islands” across Europe where
data is shared, or not, based on geography or public policy sectors (health, financial services for
instance).
This being said, opening a common set of rules to the voluntary adhesion of Member States looks like
the surest way to secure commitment and unqualified contribution to implement a scheme based on
a Charter whose principles will be drawn by the participants themselves.
It is also critical to develop the SRA Charter in tight keeping with other major ongoing endeavours
such as the Data Protection Regulation and the TTIP. In addition the SDA should – as the European
Cloud Strategy as a whole – focus on using open standards and ensuring interoperability of
technologies. Adherence to these principles is critical in a multi-lateral environment, such as the
proposed Shared Data Area that would stretch across many member states and nations.
Should these precautions - and other challenges likely to be found on the way of this worthwhile
initiative - be addressed properly, the original goal strongly supported by our industry of an extended
harmonization for the benefit of a freer flow of better protected data will be met. DIGITALEUROPE
will be happy to assist the Commission in delivering on this main avenue towards growth, jobs and
improved competitiveness in Europe.
DIGITALEUROPE
Rue de la Science, 14 >> B-1040 Brussels [Belgium]
T. +32 2 609 53 10 >> F. +32 2 609 53 39
www.digitaleurope.org
Transparency register member for the Commission: 64270747023-20
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ABOUT DIGITALEUROPE
DIGITALEUROPE represents the digital technology industry in Europe. Our members include some of
the world's largest IT, telecoms and consumer electronics companies and national associations from
every part of Europe. DIGITALEUROPE wants European businesses and citizens to benefit fully from
digital technologies and for Europe to grow, attract and sustain the world's best digital technology
companies.
DIGITALEUROPE ensures industry participation in the development and implementation of EU
policies. DIGITALEUROPE’s members include 57 global corporations and 36 national trade
associations from across Europe. In total, 10,000 companies employing two million citizens and
generating €1 trillion in revenues. Our website provides further information on our recent news and
activities: http://www.digitaleurope.org
THE MEMBERSHIP OF DIGITALEUROPE
COMPANY MEMBERS:
Acer, Alcatel-Lucent, AMD, APC by Schneider Electric, Apple, BenQ, Bose, Brother, Canon, Cassidian,
Cisco, Dell, Epson, Ericsson, Fujitsu, Hitachi, HP, Huawei, IBM, Ingram Micro, Intel, Jabil, JVC Kenwood
Group, Kodak, Konica Minolta, Lexmark, LG, Loewe, Microsoft, Mitsubishi Electric, Motorola Mobility,
Motorola Solutions, NEC, Nokia, Nokia Siemens Networks, Océ, Oki, Oracle, Panasonic, Philips,
Pioneer, Qualcomm, Research In Motion-Blackberry, Ricoh International, Samsung, SAP, Sharp,
Siemens, Sony, Swatch Group, Technicolor, Texas Instruments, Toshiba, TP Vision, Xerox, ZTE
Corporation.
NATIONAL TRADE ASSOCIATIONS:
Belgium: AGORIA; Bulgaria: BAIT; Cyprus: CITEA; Denmark: DI ITEK, IT-BRANCHEN; Estonia: ITL;
Finland: FFTI; France: Force Numérique, SIMAVELEC, Syntec Numérique ; Germany: BITKOM, ZVEI;
Greece: SEPE; Hungary: IVSZ; Ireland: ICT IRELAND; Italy: ANITEC; Lithuania: INFOBALT; Netherlands:
ICT OFFICE, FIAR; Poland: KIGEIT, PIIT; Portugal: AGEFE; Romania: APDETIC; Slovakia: ITAS; Slovenia:
GZS; Spain: AMETIC, Sweden: Foreningen Teknikföretagen, IT&Telekomföretagen; United Kingdom:
INTELLECT
Belarus: INFOPARK; Norway: IKT NORGE; Switzerland: SWICO; Turkey: ECID, TESID, TÜBISAD;
Ukraine: IT UKRAINE.
DIGITALEUROPE
Rue de la Science, 14 >> B-1040 Brussels [Belgium]
T. +32 2 609 53 10 >> F. +32 2 609 53 39
www.digitaleurope.org
Transparency register member for the Commission: 64270747023-20
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