EU’s Data Strategy sought two complementing measures (1) an enabling legislation for governance of EU’s common data spaces, the now draft Data Governance Act (DGA), and (2) a more substantive legislation governing relations among various data actors, including laying out rights of data access and use.
IC
IT for Change
NGO · IND
not in the EU Transparency RegisterThis organization files on consultations without a register number, so its record here is built from its filings alone. Register facts (staff, costs, accreditations) are not available for it.
4
positions filed
in the 665 files tracked
3
legislative files
of 665 tracked
4
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 665 consultation files tracked so far (57,774 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
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Their record over time
IT for Change filed 4 positions between 30 Jun 2020 and 25 Jun 2021, across 3 of the 665 legislative files tracked here, attaching a full position paper 4 times.
2020 · 1 filed2021 · 3 filed
What they argued
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.
Regarding the data access provisions of the DMA, we have two comments: 1. The provision for giving business users access to data generated through their activities and of respective end users can have transformational impact on the relative power of dominant platforms and their business users. Such access is rightly both for aggregate and non aggregate data, and personal (with safeguards) and non personal data.
We acknowledge the recognition that the Platform-to-Business Regulation (Regulation) is the first step to regulate the platform economy. We appreciate its focus on influencing the contractual terms and bargaining position between the platforms and the business users it hosts. However, transparency and measures of redress are not enough to deal with extraordinary platform power.
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Turns up on the same files
Organizations that also filed on at least two of the same consultations. A shared interest in the same dossiers, not evidence of coordination, and we do not suggest any.
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