European data governance (Data Governance Act)

In our submission, we focus on discussing the proposal from a perspective that acknowledges the fundamental role played by Open Access Commons-based data sharing in the overall data ecosystems. Please find the full submission in the attached document.

Nokia regards the DGA as an important initiative in the context of EU’s ambitious Data Strategy. The DGA proposal demonstrates the EU’s understanding of the importance of data-driven innovation for the future of humanity. We believe that facilitating access to, and availability of data in a trustworthy environment form the crux of a successful digital economy, being key enablers of innovation and societal progress.

CEN and CENELEC welcome the proposal for a Regulation on European Data governance and invite the European Commission to make use of the European standardization system to support the EU policy objectives. The CEN and CENELEC feedback is enclosed to this consultation.

If done right, the European Commission’s initial proposal on the Data Governance Act (DGA) has the potential to be an important step towards a European data economy. While previous discussions about the use of data have focused primarily on the important topic of data protection, there is an increasing awareness for the innovative potential of data, which is why we welcome that the DGA addresses all types of data…

We welcome the proposal of ‘Data Governance Act’, with the aim to create a truly integrated data market in the EU. Our association highlights the importance of regulating data with the same tools than other production factors. Given that a land, labour, physical and human capital markets exist, there should exist data market with transparent prices and homogeneity of the production factor.

The Open Data Institute (ODI) is an independent, non-partisan, not-for-profit organisation founded by Sir Nigel Shadbolt and Sir Tim Berners-Lee in 2012. The ODI wants data to work for everyone: for people, organisations and communities to use data to make better decisions and be protected from any harmful impacts. We work with companies and governments to build an open, trustworthy data ecosystem.

A group of representatives of the PharmaLedger project welcome the opportunity to provide feedback on the European Commission’s proposal for a Regulation on European data governance (Data Governance Act) COM(2020)767.

A group of representatives of the PharmaLedger project welcome the opportunity to provide feedback on the European Commission’s proposal for a Regulation on European data governance (Data Governance Act) COM(2020)767.

We congratulate the European Commission teams who have been working hard on the Data Governance Act proposal. It is not an easy task to bring forward a groundbreaking regulation. We welcome the regulation as a needed common ground for clarifying the role of data intermediaries, building trust in these intermediaries, and setting the direction for data governance, similar to what GDPR did for data protection.

Dear EU representative, Thanks to EU for driving better digital environment forward. There is really high hope make Europe even better place be live in. Summary of feedback 1. Directive structure to be clarified 2. Technical aspects to be taken out from the directives There is more details in the attached file. Best Regards, [name removed]

Dear EU representative, Thanks to EU for driving better digital environment forward. There is really high hope make Europe even better place be live in. Summary of feedback 1. Directive structure to be clarified 2. Technical aspects to be taken out from the directives There is more details in the attached file. Best Regards, [name removed]

Dear EU representative, Thanks to EU for driving better digital environment forward. There is really high hope make Europe even better place be live in. Summary of feedback 1. Directive structure to be clarified 2. Technical aspects to be taken out from the directives There is more details in the attached file. Best Regards, [name removed]

The draft Data Governance Act (DGA) is a welcome move by the EU to enter the area of economic governance of data. It is a part of the EU’s Data Strategy’s effort to make EU "the most data-empowered continent in the world” and swing the power away from large tech companies.

General Comments The Japan Business Council in Europe (JBCE) supports the European Commission's efforts to create a trusted and interoperable data sharing environment in the EU and welcomes the general idea of Data Governance Act (DGA) which sets ambitious goals for creating trust in data intermediaries and strengthens data-sharing mechanisms across the EU.

Dear EU representative, Thanks to EU for driving better digital environment forward. There is really high hope make Europe even better place be live in. Summary of feedback 1. Directive structure to be clarified 2. Technical aspects to be taken out from the directives There is more details in the attached file. Best Regards, [name removed]

Dear EU representative, Thanks to EU for driving better digital environment forward. There is really high hope make Europe even better place be live in. Summary of feedback 1. Directive structure to be clarified 2. Technical aspects to be taken out from the directives There is more details in the attached file. Best Regards, [name removed]

Geens NPO is one of the 27 MyData Operators. A growing group of data operators that actively implement the human-centric MyData Principles. As part of this group, we endorse the fuller response being delivered by the combined MyData Operator group. We welcome this proposal and thank all involved for their hard work in this important and very European regulation.

The European Data Governance Act is another progressive indication that the EU is seeking to develop a more equitable digital economy. However, where we go from here depends on how the European Union is able to use the Data Governance Act to strike a balance between the existing tech giants and data platforms alongside an entirely new range of services designed to enable the collection, protection and exchange of…

Sensotrend is a health-tech startup and a founding member of the MyData Global organization. We appreciate the goals of the Commission and support the aims of creating a single market for data, where data from public bodies, business and citizens can be used safely and fairly for the common good. To get there, the Data Governance Act is a good step.

Fair&Smart offers ethical solutions for personal data management to individuals and organisations since 2016. We welcome the opportunity to comment on the publication of the Data Governance Act which is another incredibly valuable and groundbreaking regulation. Congratulations to the teams involved.

HERE Technologies appreciates the opportunity to provide feedback on the proposed Data Governance Act. Enhancing data availability, access and re-use are prerequisites to develop a fully-fledged EU Data Economy and pave the way for EU Digital Sovereignty, that both Member States and the European Commission are aiming for.

COCIR welcomes the opportunity to provide feedback to the European Commission’s proposal for a Data Governance Act. COCIR has in the past presented its views on the European Strategy for Data as well as on the inception impact assessment of a data governance framework for common European data spaces.

Our main points for potential improvements are: 1. Explicitly include individuals as active participants in the definitions: define the key roles in data sharing (Art. 2 Definitions) so that data rights holders (data subject) and technical data holders (controller or processor) can be separated and acknowledge the type of data sharing where individuals are active participants in the transactions 2.

Vastuu Group Oy is participating in Data Governance Act commentary as a Finnish SME focusing on fair data economy and sustainable data sharing activities. Our business consists of human-centric data sharing as functional MyData Operator and data-driven ecosystem sensitive public-private-partnerships.

Huawei supports the Commission in its attempt to stimulate the data market and appreciates this opportunity to comment on the proposal for a Data Governance Act. Huawei is not a data company per-se but our technologies are cost-efficient enablers for data sharing services and industry initiatives. Due to this we have the expertise to comment on the current proposal and feed into the legislative debate.

aNewGovernance welcomes the publication of the Data Governance Act. Following on our response to the overall EU Data Strategy, we support the European Commission’s actions encouraging data sharing and reuse, thus unlocking the yet unexploited financial and societal value of data. Building on our previous contributions, we would like to precise the following points: 1.

Technology Industries of Finland (TIF) represents more than 1,600 companies operating in Finland in various areas of technology. In Finland, the technology industry directly employs more than 300 000 people. Technology Industries of Finland regards the Data Governance Act a key piece of regulation and would like to provide the following comments: Chapter I Concept of Data Sharing Service Provider should be defined.

Unlocking the potential of data Instrat Foundation strongly supports initiatives aimed at opening up data and making it more accessible to the general public. As part of the Energy and Environment research program, in 2020 we launched the first Polish data hub with open access data on energy, mining, and climate - the energy.instrat.pl platform.

Dear Madam, dear Sir, I am pleased to submit the contribution of SMEunited to the consultation on DGA under the form of a position paper that you will find attached. If you have questions, please do not hesitate to contact me. Kind regards, [name removed]

MyLife Digital Ltd who are one of 27 MyData Operators, would like to congratulate the European Commission teams who have been working hard on the Data Governance Act proposal. It is not an easy task to bring forward a groundbreaking regulation.

The openness of public sector data in general is a factor in the diffusion of innovation for society in general but also for enterprises. However, the openness of public sector data should not be confused with the dissemination of data produced by private companies, which constitute a real “source of value”.

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MyLife Digital Ltd who are one of 27 MyData Operators, would like to congratulate the European Commission teams who have been working hard on the Data Governance Act proposal. It is not an easy task to bring forward a groundbreaking regulation.

MedTech Europe welcomes the opportunity to respond on the proposal for a European Data Governance Act (DGA). We support the European data strategy and specifically the sectoral project of the European Health Data Space. THE MEDTECH INDUSTRY delivers products, services or solutions that improve prevention, diagnosis, treatment, monitoring and management of health and lifestyle.

EURORDIS represents 30 million people living in Europe with one or more of over 6,000 identified rare diseases. We welcome the opportunity to submit our observations to the Data Governance Act (DGA) as we believe that it should contribute to derive value from health data to improve healthcare services, research and policymaking while protecting people’s privacy and respecting their preferences.

General comments Insurance Europe welcomes the overall objective of the European Commission to create a single market for data, where data from public bodies, businesses and citizens can be used safely and fairly for the common good.

Gisad’s opinion is subject to the proviso that it is part of an overall digital concept (multiple use of the same infrastructure at no extra cost). Gisad has defined three objectives on which a Digital Marshall Plan should focus: 1. The optimal processing and easy exploitation of digital data, while preserving diversity and involving all those involved in the value added in a merit-based manner. 2.

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Gisad’s opinion is subject to the condition that it is part of a digital whole, concept (multiple use of the same infrastructure at no extra cost). Gisad has defined three objectives on which a Marshall Plan should focus: 1. Optimal processing and easy use of digital data, while preserving diversity and suffering. ensure that all those involved in the creation of value are involved in a fair manner. 2.

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DIGITALEUROPE welcomes the proposal for a Data Governance Act (DGA) and the possibility to provide feedback to the Commission. We are still finalising an in-depth analysis, but we already share below a set of early comments. Scope: The scope of the DGA needs to be clarified.

DataYogi is a MyData Operator, so let us begin by saying that we endorse the fuller response being delivered by the combined MyData Operator group. We wish to add two further comments that are from our specific perspective: Firstly, we would further emphasise that it is frustrating to see that yet again, the individual is not a full actor within the eco-system envisaged around data governance.

Art 11(1) reads: ‘the provider may not use the data for which it provides services for other purposes than to put them at the disposal of data users and data sharing services shall be placed in a separate legal entity’. Our organization Onecub (www.onecub.com) offers a data-sharing intermediary solution.

title: THE COMBINATION BETWEEN SOCIAL AND ECONOMIC SUSTAINABILITY FOR A GENUINE PEOPLE-CENTRIC ETHICS topic: People must remain constantly at the centre of the new forms of data intermediation and purposes. To ensure this, in addition to the needed legal entities, it should be clarified that intermediary’s neutrality does not mean limited business models if these models are based on a solid, verifiable combination…

Why-Advisory Oy is participating as founder and advisor in data-driven economy initiatives like the Real Time Economy program, MyData.org and FIndy (Finnish Indy). The Data Government Act can be a seminal step towards make data flow as freely between senders and receivers as e-mail and payments do presently.

HIMSS welcomes the proposal for a Regulation on Data Governance, which it believes will provide a much-needed governance framework for the sharing of data to build a stronger data-based economy in Europe and worldwide.

We welcome the ambitions of the European Commission’s proposal, which will help to strengthen the data economy, to the benefit of both businesses and the public sector. This proposal represents an opportunity to stimulate data sharing at the European Union level. In addition to our response to the previous European consultations, we would like to formulate in the attached document some additional elements.

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The Centre for Information Policy Leadership (CIPL) welcomes the opportunity to respond to the Commission’s Consultation on the proposed Data Governance Act (DGA). The DGA is an important step within the EU’s broader Data Strategy, as it focuses on facilitating data access and availability while enabling and promoting trust in data sharing.

We welcome the ambitions of the European Commission’s proposal, which will help to strengthen the data economy, to the benefit of both businesses and the public sector. This proposal represents an opportunity to stimulate data sharing at the European Union level. In addition to our response to the previous European consultations, we would like to formulate in the attached document some additional elements.

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Mastercard welcomes the opportunity to provide feedback to the European Commission on its proposed Data Governance Act (“DGA”) as part of the public consultation on Data sharing in the EU – common European data spaces (new rules).

FREE NOW comment on the Data Governance Act Founded in 2009 as one of the world's first taxi ride-hailing apps in Hamburg, FREE NOW (formerly mytaxi) has become one of the largest intermediaries for mobility services in Europe. In addition to our ride-hailing services we also provide e-bikes, e-scooters, e-mopeds and car-sharing.

BDVA/DAIRO welcomes the possibility to provide feedback to the public consultation on Data Sharing in the EU – common European data spaces and more particularly on the Data Governance Act and its inception Impact Assessment.

First of all, we welcome European Commission’s removal of an explicit data localisation requirement for sensitive personal data and sensitive commercial information and the fact that the Regulation no longer has explicit data localisation rules.

• EIT Health welcomes the legislative proposal for the Data Governance Act (DGA), noting that it provides for the adoption of sector specific legislation for sectoral data spaces which will build on the provisions of the DGA and will apply in complement to it. EIT Health looks forward to providing comment on such draft legislation.

In November 2020, the European Commission released the proposal for a Regulation on Data Governance, the first set of measures within the European data strategy framework. This proposal for a Regulation establishes a legislative framework for the governance of the European Common Data Spaces and to ensure that the measures taken by Member States are coordinated with a view of creating a single market for the…

MEDEF welcome this proposal for a regulation, the first part of the European data strategy, which aims to promote the availability of data and to regulate data sharing services. However, this proposal for a regulation raises a lot of questions as to its scope and how it reports with European texts (in force or under discussion), such as the DSA/DMA or the future data act, and with initiatives such as Gaia-X and the…

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In light of the increasing digitalisation in the healthcare sector which was accelerated by the current COVID-19 pandemic, the Austrian Social Insurance warmly welcomes the European Commission’s proposal for introducing a European Data Governance fully in line with EU values and principles bringing significant benefits to EU citizens and companies.

techUK welcomes several positive aspects about the proposal and commends efforts to promote trusted data-sharing. However, techUK members would like the European Commission to consider the following recommendations: Greater clarity is needed on the scope of data sharing intermediaries and what is meant by publicly held ‘protected data’ and ‘highly sensitive data’.

While welcoming several positive aspects about the proposal and commending efforts to promote trusted data-sharing, techUK members would like the European Commission to consider the following recommendations: The scope and requirements for data intermediaries should be clarified.

The NGI Forward team at Nesta welcomes this opportunity to respond to the European Commission’s proposal for the Data Governance Act. We find this proposal an important step towards a common and competitive European framework for sharing of both industrial and personal data. In the attached document, we set out areas that we believe could benefit from reconsideration or additional clarifications, including: 1.

The ECHAlliance is a global network of Digital Health Alliances that connects 78 countries in Europe, USA, Canada, China, Africa, Asia, the Caribbean and Americas and the Pacific, including stakeholders from government, health & social care providers, companies and start-ups, researchers, insurances, patient groups and citizens.

RELX welcomes the opportunity to provide feedback on the European Commission’s proposal for a Data Governance Act. RELX welcomes the Commission’s call on public authorities to adopt policies that encourage and enable greater sharing of public sector data.

The German Medical Association (Bundesärztekammer) is the central organisation in the system of medical self-administration in Germany. As the joint association of the State Chambers of Physicians (Landesärztekammer), it represents the interests of more than 526,000 physicians in matters relating to professional policy, and plays an active role in opinion-forming processes with regard to health and social policy and…

Vodafone welcomes the publication of the Data Governance Act. As set out in our response to the overall EU Data Strategy, Vodafone wholeheartedly supports the objective of the European Commission to encourage data sharing and reuse and thereby unlock the latent value of data. Our detailed comments are attached.

The Data Governance Act proposal is a key legislative initiative to promote the availability of data for re-use, increase trust in intermediaries, and strengthen data exchange mechanisms across EU cities. Local governments recognise citizen data as a public asset that should be accessible, shareable, and used to create value for citizens.

CER believes that data and digitalisation provide new opportunities throughout logistics and mobility systems, and for EU citizens and businesses. Moreover, efforts to digitalise the transport sector will also contribute to achieving the EU Green Deal objectives.

In general terms: we welcome this initiative and we consider it extremely necessary as it regulates the data sharing processes in order to maximize the utility of public data within the constraints of protection, privacy and property of such data.

Given the upcoming proposal for a European Health Data Space (EHDS), EPF welcomes the request for a regulation on European data governance (Data Governance Act), which will serve as a horizontal framework for data governance across the different sectoral data spaces.

Statement and amendments proposed by the German Social Insurance of 01 February 2021 The German Federal Pension Insurance (DRV Bund), the German Social Accident Insurance (DGUV), the National Association of Statutory Health Insurance Funds (GKV-Spitzenverband) and the national associations for statutory health and longterm care insurance funds and the Social Insurance for Agriculture, Forestry and Horticulture…

In letter our views, groups and suggestions are listed below, a more elaborate feedback is available in the uploaded letter. Due to the nature of their work, our members find themselves in a position where data plays a predominant role. Large amounts of data from an AMPLE variety of sources ensures both businesses and organisations can find new opportunities to innovate and develop.

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The International Data Spaces Association (IDSA) applauds the proposal of the Data Governance Act (DGA) as an important milestone towards achieving sovereignty, security and interoperability in the European data spaces architecture.

The Open Data Institute (ODI) is an independent, non-partisan, not-for-profit organisation founded by Sir Nigel Shadbolt and Sir Tim Berners-Lee in 2012. The ODI wants data to work for everyone: for people, organisations and communities to use data to make better decisions and be protected from any harmful impacts. We work with companies and governments to build an open, trustworthy data ecosystem.

Enel SpA, a multinational company in the energy sector highly appreciates the EC initiative to support the creation of a European data economy promoted by data sharing across sectors and Member States. The Enel Group appreciates that in the proposal data sharing remains a choice and considers that sharing privately-held data should remain voluntary.

Air Liquide serves a very wide variety of customers around the world and acts as a partner to nearly every sector of the economy. Digital transformation and opportunity is core to our activities.The Group’s presence in the field, alongside small businesses, large companies and healthcare professionals alike, enables it to detect new needs, develop a detailed understanding of the changes in various markets.

GFII Contribution on the proposal for a Data Governance Act (01/02/2021) • Making “protected data” available for user should be mandatory, in compliance with DGA requirements • The possibility to have different anonymity levels according to to the end users’ categories of the reuser and the purpose of Reuse should be considered • BtoB datasharing requests more than feasibility; It requesters to improve all…

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The Association of Consumer Credit Information Suppliers (ACCIS) and the Federation of leading Business Information Services Providers (FEBIS) appreciate the opportunity to comment on the European Commission’s proposal for a Data Governance Act.

STM welcomes the ambition of the European Commission to create a single market for data, facilitated by clearer, harmonised rules for data exchange and by increased trust between citizens, businesses and public sector bodies (PSBs). We appreciate the possibility to provide feedback to the proposed Data Governance Act (DGA).

E.ON appreciates the opportunity to participate in the European Commission's consultation process on the Data Governance Act. E.ON is open to and supports any initiative strengthening the European digital economy.

Roche views the proposed DGA as a very positive development and is supportive of the Commission’s intent to enhance data flow and improve data sharing. Roche supports the aim of the DGA in line with its feedback to both the European Strategy for Data and the Legislative Framework for the Governance of Common European Data Spaces.

The Association for Financial Markets in Europe (AFME) welcomes the opportunity to comment on the European Commission’s proposal for a Regulation on European Data Governance (Data Governance Act). AFME represents a broad array of European and global participants in the wholesale financial markets.

Digitalization will in the longer run bring about increased efficiency and productivity. Good data management is a prerequisite to bringing about this change and in creating an up-to date EU digital alternative where EU law prevails. In this context the City of Stockholm welcomes the Data Governance Act and the EUs high ambitions concerning digitalization.

We see that the Data Governance Act is attempting to achieve two main aims. Firstly, to enable a data market, where companies can effectively ‘trade’ data, and secondly, to enlarge the pool of data available in Europe for R&D and innovation purposes. Both are integral for the realisation of the European Data Lake and the nine Common Data Spaces.

OPEN DEI, representing a cluster of EU funded projects and large-scale pilots, welcomes the DGA and proposes the following recommendations co-authored by the projects. These are explained more fully in the accompanying PDF. We welcome the proposed role of the data intermediary, but recommend that the permitted roles in the content of eHealth are worked out in more detail, with a view to labelling/certification.

BDI welcomes the European Commission's proposal for a regulation on European data governance to promote the increased reuse of data held by the public sector, support for voluntary data sharing by intermediaries, interoperability and standardization measures. In order to realize a smooth data flow EU-wide and through cross-sector value chains, a harmonized legal environment across Europe is needed.

The European Alliance for Research Excellence (EARE), a coalition of companies and research organisations formed in 2017 committed to the future of innovation and R&D in Europe, warmly welcomes the possibility to comment on the European Commission’s draft Data Governance Act.

The European Banking Federation (EBF) welcomes the opportunity to respond to the European Commission’s consultation on its published Data Governance Act. While the EBF recognizes that the different elements of the Regulation are a step towards helping to create a Single Market for Data in the EU, we would encourage more ambition in future proposals, notably on the Data Act, to increase access data across different…

Please see a short summary of the comments of the German Insurance Association (GDV) below. For the complete feedback please see the document in attachment. Re-use of data held by public sector bodies GDV supports the notion that public sector data is made more easily available for re-use. For example, such data can benefit insurance in terms of risk modelling or damage prevention.

The European Data Centre Association (EUDCA) represents the European data centre operator community. The EUDCA is happy to submit feedback on the new rules for the common European data spaces and wants to draw attention to the following key points: • Colocation DCs provide space, power, cooling, and physical security for the server, storage, and networking equipment of other firms.

Dear Sir/Ms, please find the attached administraive non-paper from the Ministry of Government Administration and Reform in Norway. Please be aware that we suggest in the non-paper that it could be of interest to have a web-meeting with the Commission (G1), especially related to article 5 in the proposed regulation.

The goal of the European Commission’s proposal for an EU “Data Governance Act”(DGA) is to foster the availability of data, in particular non-personal data, for (re-)use by increasing trust in novel data intermediary services and strengthening data-sharing mechanisms across the EU.

Achieving the promise of the digital economy will require robust data governance frameworks that allow data sharing – helping develop new data-enabled products and services – while protecting individual rights and freedoms. In pursuit of this aim, the Data Trusts Initiative welcomes the opportunity to response to this consultation on the draft Data Governance Act.

The Austrian Chamber of Commerce (Wirtschaftskammer Österreich) is the legal representative of the whole Austrian economy and represents all Austrian companies — around 540.000 businesses in the areas of crafts and trades, industry, commerce, banking and insurance, information and advice, tourism and leisure, transport and communication. 99.6 % of our members are SMEs with fewer than 10 employees. I.

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We (the Association Française Transhumaniste - Technoprog) consider that many proposals of the European Union concerning databases are positive. This is especially the case when they contribute to more open science in the spirit of article 27 of the UDHR (right to share in scientific advancement and its benefits). We are particularly positive concerning the proposals about "altruist databases".

We (Heales, Healthy Life Extension Society) are happy to see that many proposals of the European Union concerning databases are positive. This is especially the case when they contribute to more medical knowledge in order to make people healthy like defined in the constitution of the World Health Organization (Health is a state of complete physical, mental and social well-being and not merely the absence of disease…

Legacoop Nazionale welcomed the new regulation proposal published on 25 November 2020 by the European Commission on data governance which, moreover, is part of the strategy for creating a single digital European market based on "data sharing", with characteristics aiming to "harmonize" economic goals with the defense of individual rights, privacy and a recovery of that ethical and collaborative spirit that was the…

The purpose of Chapter II is to provide for re-use of data which is subject to third party rights. In recognition of the fact that this goal involves a delicate balancing act, we offer the following comments in support of clearer protections for those third party rights: IPRs Chapter II applies to data held by a public sector body (PSB) which is protected on grounds of, inter alia, “protection of IPRs of third…

The European Data Governance Act (DGA) seeks to put the sharing and (re-)use of protected data - including public sector data - on a legally reliable and economically attractive basis by creating new forms of fiduciary data intermediaries (data sharing providers, hereinafter DSPs), which do not exploit the data themselves, but take stock of these data, prepare them for ap-propriate use and distribute them.

ICC feedback on the Proposal for a Regulation - COM(2020)767 on European Data Governance - Please see more detailed feedback in the attached document. ICC greatly values and supports the objectives of the Proposal, namely increasing the availability of data for use by building trust in data intermediaries and strengthening data-sharing mechanisms across the EU.

ICC feedback on the Proposal for a Regulation - COM(2020)767 on European Data Governance ICC greatly values and supports the objectives of the Proposal, namely increasing the availability of data for use by building trust in data intermediaries and strengthening data-sharing mechanisms across the EU.

Business & Science Poland welcomes and appreciates the European Commission’s efforts in boosting innovation among the European industry. Together with our members, we recognize a need to strengthen digital capabilities among European companies and also a broad potential that it offers.

Access Now welcomes the opportunity to provide comments on the European Commission’s proposal for a Data Governance Act (DGA) to inform the upcoming legislative debate in the European Parliament and in Council. The DGA marks an objectionable shift in the European Commission’s approach to the governance of personal data, where the focus moves from empowering people to empowering the data economy.

EFPIA • Welcomes the Data Governance Act as an important milestone in the delivery of the EU’s Data Strategy • Hopes the act will address fragmentation in the implementation and interpretation of GDPR and underpin the agreed flexibilities of GDPR in relation to scientific research • Believes that the new data intermediation entities have the potential to improve data access for researchers but must operate…

EFPIA • Welcomes the Data Governance Act as an important milestone in the delivery of the EU’s Data Strategy • Hopes the act will address fragmentation in the implementation and interpretation of GDPR and underpin the agreed flexibilities of GDPR in relation to scientific research • Believes that the new data intermediation entities have the potential to improve data access for researchers but must operate…

Bridgestone welcomes the opportunity to provide its feedback on the proposal for a Regulation on European Data Governance. Bridgestone is a global leader in smart and sustainable mobility solutions and looks with great interest to the potential that the digitalization offers in the mobility domain.

ZVEI welcomes the EU Commission’s objective to increase data availability and better access to public data, as well as facilitating private data sharing by increasing trust and reducing the transaction costs. The creation of a trusted European data infrastructure will support data-driven innovations in the economy.

Orgalim in principle welcomes the proposal of the European Commission for a Regulation on European data governance (Data Governance Act – DGA) . Data access is essential for any successful data-driven business model. We share the Commission’s overall objective to foster the availability of data both by increasing trust and by strengthening data sharing mechanisms across the EU Member States.

For a founder, an idea and a dataset are the key ingredients for a successful startup. Data enables entrepreneurs to test, refine and develop products and services for the businesses and consumers that use them. As a non-rivalrous good, data can benefit many users and has no scarcity. Access to data, both within and outside Europe, is vital for startups.

Eurosmart, the Voice of the Digital Security Industry, welcomes the Commission’s proposal for a Data Governance Act. This proposal is instrumental to develop the European research and industry in the field of AI. Ultimately, it should strengthen Europe’s AI value chain, and hence its strategic autonomy. However, Eurosmart has a few recommendations to improve the content of the proposed legislation.

Workday appreciates the opportunity to provide feedback on the European Commission proposal for a Data Governance Act (“DGA”). Workday is a leading provider of enterprise cloud applications for finance and human resources, helping customers adapt and thrive in a changing world.

Overall: For most IoT ecosystems, in order to support addressing societal challenges having trusted open and dynamic data readily available as core facility, it is a prerequisite to have such data and derived data and being able to use it, to add to such ecosystems and understand how to share and otherwise being able to use such data and derived data.

Comments on the European Commission’s “Data Governance Act” 29th January 2021 Data Strategy Working Group Subcommittee on Digital Economy KEIDANREN (Japan Business Federation) Making globally harmonized rules to enable secure data use across national borders is indispensable for the high-level utilization of digital technology and data by the international community to promote economic growth and resolve social…

EuroGeographics is an independent international not-for-profit organisation representing Europe’s National Mapping, Cadastral and Land Registration Authorities. Our members are responsible for a large set of public sector datasets including high value geospatial datasets that are defined in the Open data and PSI directive and that play an important part of the overall European Strategy for data.

Dear Sir/Madam, Herewith on behalf of the Data Sovereignty Now coalition, I present our input on the Proposal for a regulation of the European parliament and of the council on European data governance (Data Governance Act).

The German Mechanical Engineering Industry Association (VDMA) represents more than 3.300 member companies in the SME-dominated mechanical engineering industry in Germany and Europe. With around 1,3 million employees in Germany and a turnover of EUR 230 billion (2019), the sector is the largest industrial employer and one of Germany’s leading sectors of industry overall.

The DGA proposal defines the concept of Data Sharing Service Provider. However, it is unclear, how mandatory the provisions are for a company sharing data. Art. 10 stipulates that "Any provider of data sharing services who intends to provide the services ... shall submit a notification", which implies that the provisions are mandatory for all the organisations providing data sharing services.

Software AG highly welcomes the Commission's objective to foster the availability of data and thus laying the foundation for a European data economy. We share the Commission's view that this requires a European approach. Isolated legislations by the Member States on data-related issues bear the risk of fragmenting the Single Market.

The Bundesdruckerei Group explicitly welcomes the European Commission's proposal as an effective legislative framework for the trustworthy and secure handling of data. The envisaged specifications for the use of Data Sharing Services (Art.

Wikimedia in Brussels (Free Knowledge Advocacy Group EU) Wikimedia believes that an online public space that is inclusive, accessible and competitive will depend on the existence of a variety of platform models and business models to choose from.

With the Data Governance Act, the EU Commission aims to facilitate the processing of data in compliance with fundamental European values. In principle, the Federation of German Consumer Organisations (vzbv) welcomes that more (non-personal) data is to be made available, i.e. from a competition perspective.

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Dear Madam, Dear Sir, EUROGI is a European-wide representation body for organisations involved in the location/geospatial industry and wants to answer to your request for comment on the Data Governance Act (DGA). We welcome the DGA and its commitment to the release of previously restricted data in order to facilitate innovation, economic growth and increased services for all citizens across Europe.

Introduction Belron appreciates this opportunity to comment on the Commission’s proposal for a Data Governance Act (DGA). As a major player in the vehicle aftermarket, we are seeing the increasing relevance of having access to data in order to continue to offer our services, and innovate and develop new services.

About eco With more than 1.100 member companies, eco is the largest association of the internet economy in Europe. Since 1995, eco has been shaping the Internet, promoting new technologies, creating framework conditions and representing the interests of its members vis-à-vis politics and in international fora.

Filed in German · English published by the European Commission

The W3C Linked data framework can be instrumental to implement the vision set out in European strategy for data. In order to do this, the legal value of metadata – in the sense of data annotations – needs to be clarified to ease the creation of data value chains considerably. This document makes a suggestion on how to encode the needed legal certainty requirement into the act.

The data ecosystem holds true potential in the data economy where our sector contributes to the objective of the Commission to foster the availability of data by both increasing trust and by strengthening data-sharing mechanisms across the EU.

Please find attached the feedback of ACT | The App Association (Transparency Reg. # 72029513877-54) to the European Commission’s Directorate-General for Communications Networks, Content and Technology on its proposal for a “Regulation on European Data Governance”. Anna Bosch Policy Associate ACT | The App Association (Transparency Reg. # 72029513877-54) Rue de Trèves 45 B-1040 Brussels

It is very welcoming that intermediaries can provide data sharing services and provide the means to access and control the data from an individual perspective. This we believe is enhancing digitalisation while complying to Regulation (EU) 2016/679 The EU data strategy is clear in its ambition to establish a level playing field to foster innovation, growth and competitiveness.

DATEV eG welcomes the opportunity to provide feedback on the European Commission’s proposal for a Data Governance Act COM (2020) 767. Data access is essential for any successful European data-driven business model. Therefore, DATEV shares the European Commission’s overall objective to foster the availability of data by both increasing trust and by strengthening data-sharing mechanisms across the EU.

EuroCommerce welcomes the opportunity to provide feedback to the European Commission’s Inception Impact Assessment for a legislative framework for the governance of Common European Data Spaces (CEDSs). The coronavirus crisis has made the need for a fair and ethical European data ecosystem more pressing than ever.

Peercraft is a member of MyData Global and supports the consultation response from this organization. We would, however, like to comment further on the specific topic of data sharing costs that the impact assessment addresses in relation to the thematic clusters (iii) and (iv).

Software AG welcomes the Commission's aim to stimulate data sharing within and across sectors in Europe, thereby creating a Single Market for data. This is more important than ever in view of the severe recession resulting from the COVID-19 pandemic. As stated by the Commission, digital business models hold enormous economic potential.

Please find attached our detailed feedback. Summary: The future EU data spaces, as outlined in the Commission’s Data strategy, will be key to create a Single Market for data that will drive the EU’s digital transformation.

COCIR welcomes the opportunity to provide feedback to the European Commission’s inception impact assessment on a legislative framework for the governance of common European data spaces. COCIR has presented its views on the European Strategy for Data and is fully supportive of the creation of common European data spaces, and in particular a European Health Data Space, which would greatly contribute to the development…

Dear Madam/Sir, The European Commission wants to get Europe fit for the digital age and is working towards the creation of a Single Market for data. This is where data flows between countries and sectors, where information is available for use in full respect of European values and rules, and where there are clear rules for access and use of the data.

Insights derived from data have the potential to make healthcare systems more sustainable, supporting the daily life of patients as well as decision-makers faced with the challenge of assessing different technologies and treatments in the context of fixed budgets.

The PSI Alliance is a European alliance of private companies that reuse public sector information/public open data as a core part of their business model. We welcome the Common European Data Space initiative. In particular the recognition that there has been a low degree of use made of data held by public sector bodies and that more needs to be done in addition to the Open Data Directive to improve the accessibility…

The Skills Alliance unites 40 organizations (universities, employers, national employment agencies, training organizations) from 6 E.U countries to experiment human centric skills data networks, share standards and governance rules. We believe in the separation of powers principle to govern the personal data spaces.

FREE NOW’s vision is to make mobility available to everyone, independent of age, income and location. FREE NOW believes and supports the objectives set out in the inception impact assessment. We believe lower transaction costs to share data, lowering the cost data use through interoperability and supporting the use of data that individuals or companies voluntarily contribute to the wider public good is positive.

EUROCITIES welcomes the initiative for a legislative framework for the governance of common European data spaces. Common data spaces can pave the way for local authorities’ improved policy making, innovation and the provision of better services to citizens. The Inception Impact Assessment (IIA) describes several challenges related to large-scale public and private data sharing.

At Microsoft we believe that sharing data can help address some of society’s biggest challenges, while driving innovation and productivity. This opportunity is reflected in the European Strategy for Data, as well our recently launched Open Data Campaign, a long-term initiative to advance a much-needed discussion about how the world uses and shares data, including the policy frameworks, tools, and technologies to…

Roche welcomes the opportunity to provide feedback to the European Commission’s Inception Impact Assessment for the Legislative Framework for the Governance of Common European Data Spaces (the “IIA”), as an important step in enabling the future EU data spaces described in the European Commission’s “A European strategy for data” (the “Data Strategy”) released earlier this year.General considerations: At large, Roche…

Vodafone welcome the publication of the European Commission Roadmap Inception Impact Assessment on the legislative framework for the governance of common European data spaces. As set out in our response to the EU Data Strategy, Vodafone wholeheartedly supports the objective of the European Commission to encourage data sharing and reuse and thereby unlock the latent value of data.

The Center for Data Innovation is pleased to submit feedback to the European Commission’s roadmap titled “Legislative framework for the governance of common European data spaces.” The European Commission published a data strategy in February 2020 with the goal of creating a single market for data.

As key actor in digital solutions and data management in the energy sector, Enedis welcome this initiative. Nevertheless, Enedis would like to bring attention on some key topics. We need: — Clear definitions of common European data spaces and ‘data altruism’ — A security framework, including cyber-security data privacy management — Regarding the energy data space, a co-herent approach of existing European…

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VdTÜV: Comments on the Common European Mobility Data Space of the EU Data Strategy, July 2020 Future legislation in the context of a European mobility data space needs to take greater account of elements of data management, including ethical considerations related to the use of personal data.

Filed in German · English published by the European Commission

Common European Data Spaces need to be accessible to all market participants and enable an ecosystem where all can use and access data in a trusted, safe and secure environment. A regulatory framework for data governance should lay out high-level rules for open, transparent and structured stakeholder involvement and decision-making processes.

MyData Global is an award-winning international nonprofit. The purpose of MyData Global is to empower individuals by improving their right to self-determination regarding their personal data. It is based on the MyData Declaration, published in 2017. MyData Global has nearly 90 organisation members and over 400 individual members from over 50 countries, on six continents.

A European Strategy for Data, published by the EU on February 19th, 2020 outlines a vision for a connected single digital market, where the benefits of the digital economy could enhance the lives of its citizens, residents and trade partners. However, we now find ourselves at a very real crossroad. A post-pandemic world will be a new type of normal.

Fraunhofer Innovation Centre for Logistics and IT (FILIT) is jointly run by Fraunhofer Institute for Software and Systems Engineering (ISST) and Fraunhofer Institute for Material Flow and Logistics (IML). FILIT welcomes the opportunity to provide feedback to the Inception Impact Assessment of the European Commission for a legislative framework for the governance of common European data spaces.

The communication from the EU Commission mentions the need to tackle the problems with a cross-sector relevance in four thematic clusters. Among them, we focus on: - lower the cost of data use through interoperability at the technical level and availability of generic enabling standards; - lower transactions costs in data sharing by supporting an emerging offer of data intermediaries.

EUROGI’s mission is ‘to promote the widespread and effective use of geospatial information and technologies in Europe’. Given the role of location, where, in virtually all decision-making from high level policy to citizens’ day-to-day activities we believe that if well organised, geospatial information and technologies can play a significant role in improving social welfare, the economy and the…

The European Data Centre Association (EUDCA) represents the European data centre (DC) operator community. The EUDCA is happy to submit feedback on the new rules for the common European data spaces and wants to draw attention to the following key points: • Colocation DCs provide space, power, cooling, and physical security for the server, storage, and networking equipment of other firms.

To Whom It May Concern, ESBB expresses its sincere interest in the EU Data Strategy as a timely cross-sectional initiative of high impact and benefit for citizens of Europe and beyond. ESBB is fully aligned with EU’s current data strategy proposition in general and its INCEPTION IMPACT ASSESSMENT in particular. However, ESBB likes to emphasize one aspect that could widen the scope of likely environmental impacts.

Science Europe welcomes that the European Commission consults stakeholders on its Inception Impact Assessment for a ‘Legislative framework for the governance of common European data spaces’. Science Europe Member Organisations, major national research funding and performing organisations, have a vast experience as users and producers of data.

The German Data Forum (Council for Social and Economic Data, CouncilSWD) highly welcomes the opportunity to provide its position on the roadmap for a legislative framework for the governance of common European data spaces.

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The GeoInformation (GI) sector is suffering from a chronical lack of standardization and the current crisis has only underlined this. Hence, CLGE welcomes robust legislative initiatives in this field. GI is part of the vital horizontal data infrastructure for nearly all fields of policy, government and administration. However, it’s often said that the EU is powerless, because GI is Member States responsibility.

A large number of very small pseudonymised data are already available and exploited for statistical and research purposes in the field of health and social security. In addition, in France, public services are already widely available online, in particular via the site FranceConnect, which makes it possible to make the identity of users in their public service procedures more reliable with a one-stop shop for…

Filed in French · English published by the European Commission

RELX is a global provider of information-based analytics and decision tools for professional and business customers across a range of sectors, including financial services, science, technology, medical, healthcare and energy.

o We generally agree with the overall aim of the European Commission´s Roadmap and especially regarding the reduction of transaction costs for data access, sharing and reuse for research and innovation activities. At the moment many Companies cannot access the data they need and they often face strict limitations when they want to (re-)use data.

The European Social Insurance Platform (ESIP) welcomes the roadmap on a Legislative framework for the governance of common European data spaces, towards the creation of a Single Market for data in crucial sectors such as healthcare. This would particularly benefit people in cross-border situations.

Stiftung Neue Verantwortung is an independent think tank at the intersection of technology and society. We welcome the opportunity to reply to the Inception Impact Assessment on the legislative framework for the governance of common European data spaces. We agree with your description of the problem for the largest part and see great potential in an initiative that aims to contribute to solutions to these problems.

We believe that the following preliminary perspectives are needed before creating any ex-ante rules on data spaces. 1. CONTEXTUALISATION OF INDUSTRY LED INITIATIVES: Ex-ante regulatory intervention for B2B/B2G data sharing should not be a primary goal given the competitiveness of our sector, its high investment level into R&D and data sharing initiatives and is therefore deemed premature and disproportionate.

ZALF is leading the establishment of a national research data infrastructure for agricultural sciences (NFDI4Agri). The German NFDI initiative (www.nfdi.de) seeks to improve research data sharing and management by setting up a cross-domain common infrastructure to open up and exploit data sets and to enable linking and networking data in a sustainable way in order to facilitate interdisciplinary research.

Technology Industries of Finland (TIF) warmly welcomes initiatives that enhance data usage and interoperability and would like to especially highlight importance of following factors: • Personal data is to be found on many public and private datasets. In order to put this data to use, we need to have in place solutions to provide consent and better understanding on effect of privacy enhancing technologies.

BEUC supports the general objective of enabling data access for the common good and the development of innovative services, provided that this is carried out following a “human-centric” approach and European values and fundamental rights are fully protected and respected. The consumer should always be able to decide who gets access to his or her personal data and under what conditions.

LS RIs: BBMRI, EATRIS, ECRIN, ELIXIR, EDIReX/EurOPDX, ERINHA, EU-OPENSCREEN, Euro-BioImaging, INSTRUCT Patients associations: EPIONI, European Cancer Patient Coalition, European Federation of Allergies and Airways Diseases Patients’ Association, European Institute of Women's Health, European Patients Forum, EURORDIS – Rare Disease Europe, Hellenic Cancer Federation – ELLOK, Learning for Caregivers in Europe…

The Association for Financial Markets in Europe (AFME) welcomes the opportunity to comment on the European Commission's Inception Impact Assessment (referred to hereafter as the “Assessment”) on a Legislative Framework for the governance of common European Data Spaces. AFME represents a broad array of European and global participants in the wholesale financial markets.

EFPIA reply to the consultation for the impact assessment on the legislative framework for the governance of common European data spaces EFPIA welcomes the proposal to create a horizontal legislative framework aiming to unlock the value of data, support the use of data, lower the cost of data use and transaction cost and support the development of sectoral data spaces.

The reason to enable CDS is to enlarge the pool of available information for R&E. As the GÉANT being an R&E data transporter, it is important to contribute to the inception IA with some considerations: Work out the arrangement on how to connect data from public and corporate sources to the R&E community. When developing standards, take into account existing efforts in the research community.

Arthur's Legal, Strategies & Systems strongly supports and endorses the initiative by the European Commission to create frameworks for common European data spaces. Technological innovation has transformed society along with every other sector of our economy and data is the main catalyst for this transformation. Digital is a need to have; not a nice to have.

Orgalim, Europe’s technology industries see the transition to a data-driven economy as essential for their future growth and competitiveness, as well as inevitable. Our companies are developing and providing sensor-equipped machinery, data-based services, smart production systems and intelligent products.

As the sector association of the biotechnology industry, BIO Deutschland has set itself the objective of supporting and promoting the development of an innovative economic sector based on modern biosciences. The Berlin-based association currently has over 330 members. Biotechnology is an innovation driver for the healthcare industry.

BVDW agrees that this initiative has the potential to tackle problems with a cross-sector relevance. General Elements 1) From data economy to algorithm economy- A Single Market for data should have in mind the current shift from a data economy towards a broader algorithmic economy and should therefore be designed in a way that a law framework is also expendable for a possible.

EURORDIS welcomes the opportunity to comment on this proposal for the governance of common European data spaces. The rare disease community is acutely aware of the importance of pooling and sharing data to advance research and improve health outcomes.

Bayer welcomes the European Commission agenda to make Europe fit for the digital age and its proposal to create a Common European Data Space in the fields of health and agriculture. Bayer participates in many data sharing activities because we believe in the value of data to promote scientific advances.

We welcome the opportunity to provide input to the European Commission’s plan to publish a regulatory framework on data governance for Common European Data Spaces. We prepared our feedback from the point of view of creators, authors and rightsholders seeking to be rightly remunerated in the digital era.

BDVA welcomes the objectives described in the Inception Impact Assessment, focusing on the development of a framework for the governance of common European data spaces. BDVA supports further research and experimentation on the utilisation of data, AI technologies and data-driven innovation for the good of business and society via a smart mix of technical, legal, ethical and business methods.

Eco is the largest association of internet industries in Europe, with over 1 100 member companies. Since 1995 eco has been instrumental in shaping the internet, promoting new technologies, creating framework conditions and representing the interests of its members vis-à-vis politics and in international fora.

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The European Banking Federation (EBF) supports the European Commission’s ambition to create a single market for data in the EU and welcomes the opportunity to respond to the Commission’s Inception Impact Assessment (IIA) on a Legislative Framework for the governance of common European Data Spaces.

We are delighted to be able to contribute to this ‘Legislative framework for the governance of common European data spaces’. The aim of the Agdathub is to help to improve the economic, environmental, social and societal performance of agricultural and agri-food sectors, for example by increasing the mobilisation of data for agriculture and the development of tools to facilitate the traceability of food products.

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The European Alliance for Research Excellence, a coalition of companies and research organisations formed in 2017 committed to the future of innovation and R&D in Europe, warmly welcomes the European Commission’s ambitions outlined in its Data Strategy to create common and sectoral European data spaces.

The Austrian Social Insurances welcome the aim of the roadmap concerning the legislative framework for the governance of common data spaces, namely to create a Single Market for data and therefore to improve access to and use of data. Ensuring compliance with the existing provisions under the GDPR should be the overarching principle in order to generate broad acceptance of digital tools among European citizens.

Agriculture is entering a new era: Agriculture 4.0, or the digital economy, is becoming increasingly important in the production process. The amount of data produced on agricultural holdings is growing exponentially and is of interest to many actors. This prompted FNSEA to question ownership, control over the use and sharing of data on holdings, and the creation of values that emerge from this new economy.

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IBM shares the European Commission’s vision that Common European Data Spaces shall create an enabling environment, empowering market participants to capture the data that they generate. At the heart of the data spaces are the users of data who need the certainty that their data is handled in a responsible manner.

Alliance for Internet of Things Innovation (AIOTI) believes the future of the Single Digital Market is underpinned by IoT data. In the future Internet navigation-related data will represent a minor portion of all datasets. Most of future data will be generated by IoT devices and sensors.

Market failure - data being used as an obstacle to access consumers and technical information of their vehicle It is our opinion that national and European authorities should therefore intervene both in the interest of consumers and SMEs. Action is all the more urgent because this intervention should concentrate on ensuring free choice of customers.

The European Tech Alliance (EUTA) welcomes the opportunity to provide preliminary feedback to the European Commission on its roadmap for Data Sharing in the EU - Common European Data Spaces. For more detail, we kindly invite the Commission to read our full position on the issue of data sharing and access, annexed to this submission.

The PHG Foundation welcomes the opportunity to comment on this proposal for the governance of common European data spaces. We have recently completed comprehensive research on the impact of the GDPR on genomic data processing in healthcare and scientific research which we have attached for consideration as part of the further evidence base.

Access Now welcomes the opportunity to provide feedback to the European Commission’s public consultation on the inception impact assessment on the governance of common European data spaces. We support the goal of the Commission to make more data usable for the common good for research and innovative uses in compliance with EU data protection rules.

In its European data strategy as well as in the corresponding roadmap for a legislative framework for the governance of common European data spaces, the European Commission proposes the creation of several European data spaces in certain sectors. vzbv welcomes the opportunity to provide feedback on this topic in addition to its response to the consultation on the European data strategy in May 2020.

Occitanie Data (https://occitaniedata.fr/) is a young structure initiated by the need to remove unjustified bottlenecks to the development of a data-driven economy. Two features distinguish us from other ‘data intermediaries’. First of all, the diversity of our ecosystem, which brings together both public, private and academic actors, all with the drive to promote data usage through common projects.

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The Federation of Austrian Industries (Industriellenvereinigung, IV) is a voluntary and independent organisation representing the interests of more than 4.500 member companies in the manufacturing sector, credit and insurance sector, infrastructure and industry-oriented services in Austria. On a European level, the Federation of Austrian Industries is a member of BusinessEurope.

The BDI would like to thank for the opportunity to provide feedback on the legislative framework for the governance of common European data spaces. In this respect, we refer to our statement (29 May 2020) in the public consultation process on the EU Data Strategy, in particular to our chapters A.I and A.III.

Insurance Europe welcomes the overall objectives set out in the roadmap, namely: - to make more data held by the public sector usable for research and innovative uses (ie development of new products and services); - to allow individuals to consent to greater access to their data for the common good; and - to enhance overall data use in the economy by lowering transaction costs, addressing interoperability and…

SenX is a software that proposes a global solution – Warp 10 – to manage data from sensors / IoT based on Time Series technology. We believe the world of data will be driven by Time Series technology in the near future. We explain why and how this is going to change the way we organize the governance of data including data sharing.

CEEP, the organization representing employers and enterprises providing public services and services of general interest in Europe since 1961, welcomes the opportunity to reply to the Inception Impact Assessment on the legislative framework for the governance of common European data spaces. In the enclosed opinion, we would like to emphasise some aspects of the legislative framework and highlight our position.

Federation of Craft Businesses in the automotive sector and in mobility services (FNA) would like to thank the authors of the Inception Impact Assessment on the legislative framework for the governance of common European data spaces. This information will make a substantial contribution towards an improved understanding and enforcement of the European provisions relating to the European Strategy for Data.

The creation of a harmonized and dynamic digital single market where more data is shared and (re)used between companies, individuals and public bodies to make scientific discoveries and innovative products and services, while respecting the European values, is a precondition for the future economic growth that is both socially and ecologically sustainable.

Our Vision Wikimedia Deutschland, as part of the international Wikimedia Movement provides essential infrastructure for free knowledge. Most notably, WMDE develops Wikidata, the largest free data repository, out of Berlin.

Scaleway welcomes the opportunity to input into the Commission’s consultation on Legislative framework for the governance of common European data spaces. A data-driven Europe will lead the digital transformation leveraging data for efficiency and cutting edge technological infrastructures with governance mechanisms.

Estonia supports the creation of common European data spaces to promote the availability of data and to facilitate cross-border data use within both the EU and between various sectors. This will assure better access to data and will support better organization of data.

Please find attached comments of ACT | The App Association (Transparency Reg. # 72029513877-54) on the European Commission’s Roadmap for a “Legislative Framework for the Governance of Common European Data Spaces” (Ares(2020)3480073) Anna Bosch Policy Associate ACT | The App Association (Transparency Reg. # 72029513877-54) Rue de Trèves 45 1040 Brussels

The free flow of data and strengthening the use and re-use of data in certain sectors have great potential to drive increased economic and societal benefits, but it should be done entirely under a voluntary approach. We reiterate our strong recommendation to base any future framework on the principle of voluntary sharing of data between individuals or businesses, in full respect of contractual freedom.

STM welcomes the ambition of the European Commission to lead in the data economy and harness the potential of data to serve citizens, businesses, public institutions and society at large. In particular, STM agrees that it is crucial to focus on interoperability and enabling standards to deliver on the promise of data sharing.

Main comments: * Standardization is inevitable but the availability of standards has to improve, meaning that they should be free of charge (which calls for other financing tools for standardization organization). * There needs to be a balance between standardization and regulation vs market driven and open source.

Finland strongly supports the creation of a legislative framework for the governance of common European data spaces and sees the framework as a key factor to promote and facilitate the use and reuse of data. Finland considers that the regulatory environment must facilitate innovation and support new operating models.

I am writing on behalf of the ACM Europe Technology Policy Committee; the Association for Computing Machinery (ACM) is the world's largest computer society with about 100,000 members worldwide and about 18,000 members in Europe. We strongly support the objectives stated in Section B of the Inception Impact Assessment.

The « context » paragraph shows how clear rules for access and use of the data are essential for the success of the Single Market for data but also how important it is to consider the features of the different sectors. GFII works for years on data produced and re-used by public and private professionals, whose end-users are also professionals.

CSC supports the idea of a horizontal governance model for the common European data spaces, based on a comprehensive interoperability framework, where different levels of interoperability are developed in coherence. The European Interoperability Framework, developed by the European Commission, serves as a good basis.

The German Mechanical Engineering Industry Association (VDMA) represents more than 3.300 member companies in the SME-dominated mechanical engineering industry in Germany and Europe. With around 1,3 million employees in Germany and a turnover of EUR 230 billion (2019), the sector is the largest industrial employer and one of Germany’s leading sectors of industry overall.

DATEV welcomes the objectives the EU Commission is pursuing with the roadmap on a legislative framework for the governance of common European data spaces. • In order to provide the public sector as well as the European economy and the civil society with data of sufficient quality and quantity, the public sector should take a front-runner position.

The Women’s Eco-nomic & Social Think Tank (WESTT) welcomes the opportunity to input into the Commission consultation on Legislative framework for the governance of common European data spaces. It is essential that if the EU is to deliver on President Ursula Von der Leyen’s commitments to be more competitive and have less social inequalities within Europe then increased collaboration, coordination and communication…

My feedback is based being the founder of the Real Time Economy program, a founding member of MyData.org, advisor for Findy (verified data network initiative) and member of the Finnish Council of Regulatory Impact Analysis. 1. Why?