Lobbies on dataprotection
This page lists the different lobbies' s documents calling for an extensive definition of personal data, upon the adoption process of the European Commission's Proposal for a General Data Protection Regulation.
The indicated month is when the position has been sent to Members of the European Parliament.
- 1 Corporate associations
- 1.1 AmCham, January 2013
- 1.2 Svenska resebyråföreningen, January 2012
- 1.3 European Association of Search and Database Publishing
- 1.4 European Envelope Manufacturers Association, January 2013
- 1.5 International confederation for printing and allied industries, January 2013
- 1.6 Bitkom, January 2013
- 1.7 European Small Business Alliance and Association for Competetive Technology, January 2013
- 1.8 Eurofinas,December 2012
- 1.9 Insurance Europe, December 2012
- 1.10 Leaseurope, December 2012
- 1.11 EuroISPA, December 2012
- 1.12 Association of Consumer Credit Information Suppliers(ACCIS), December 2012
- 1.13 EuroCat, December 2012
- 1.14 Insurance Europe, November 2012
- 1.15 Digital Europe, November 2012
- 1.16 European Banking Federation, November 2012
- 1.17 European Magazine Media Association and European Newspapers Publisher’s Association, November 2012
- 1.18 Coordination Committee for the Medical Imaging, Electromedical Equipment and eHealth Industry, November 2012
- 1.19 European Association of Craft, Small and Medium-sized Enterprises, November 2012
- 1.20 The German Federal Bar, November 2012
- 1.21 AmCham EU, October 2012
- 1.22 BusinessEurope, October 2012
- 1.23 French Banking Federation, October 2012
- 1.24 GSMA/ETNO, October 2012
- 1.25 Confederation of Employers and Industries of Spain, October 2012
- 1.26 European Association of Search and Database Publishing, October 2012
- 1.27 Zentralverband der deutschen Werbewirtschaft, October 2012
- 1.28 Handelsverband Deutschland, October 2012
- 1.29 Insurance Europe, September 2012
- 1.30 EuroCommerce, September 2012
- 1.31 Luxembourg Business Federation, July 2012
- 1.32 The German Federal Bar, June 2012
- 1.33 Digital Europe, March 2012
- 2 Companies
- 2.1 EU companies
- 2.2 US Companies
AmCham, January 2013
Svenska resebyråföreningen, January 2012
European Association of Search and Database Publishing
European Envelope Manufacturers Association, January 2013
International confederation for printing and allied industries, January 2013
INTERGRAF urges to reject ammendments 81 and 135, as it fears a law targeted at the digital world would impact the direct mail business, which also relies on collecting data and sending out mailings (albeit physical). Their claim is that no one is quesitoning the handling of personal data by postal direct mail operators.
Bitkom, January 2013
European Small Business Alliance and Association for Competetive Technology, January 2013
Eurofinas is the representing lobby for consumer credit providers in Europe. In this document, it's suggesting amendments to the ITRE draft opinion. Those amendments aim at reviewing the definition of personal data and date subjects in an extensive way, allowing the companies to process, use and disseminate personal data freely, without any obligation to inform its consumers.
Insurance Europe, December 2012
Insurance Europe is the representing lobby for Insurance Federations in Europe. In its comments and definitions on the ITRE draft proposal, it's pushing for a limitation of consumer's right to access their data, in the name of business and competition.
Leaseurope, December 2012
Leaseurope is the representing lobby for car rental companies. On the pretext of heavy administrative changes for its members and in the name of business, it's supporting the less protective amendments for citizens, denying them the right to control their data.
EuroISPA, December 2012
Association of Consumer Credit Information Suppliers(ACCIS), December 2012
EuroCat, December 2012
Insurance Europe, November 2012
Digital Europe, November 2012
Digital Europe is the representing lobby for European digital technology industry. Among its members stand Apple, Microsoft, Nokia... (see last page of their document). Among the 64 amendments proposed by the organisation, modifications are made to water down obligations concerning data breaches notifications to the data subject.
European Banking Federation, November 2012
The European Banking Federation is the representing lobby for European banks. As most of the other lobbies, its proposed amendments aim at softening obligations concerning data breaches 24h notification, limitation of profiling and procedure of consent. All of these amendments go against citizens fundamental freedoms.
European Magazine Media Association and European Newspapers Publisher’s Association, November 2012
Coordination Committee for the Medical Imaging, Electromedical Equipment and eHealth Industry, November 2012
European Association of Craft, Small and Medium-sized Enterprises, November 2012
The German Federal Bar, November 2012
AmCham EU, October 2012
BusinessEurope, October 2012
French Banking Federation, October 2012
GSMA/ETNO, October 2012
Confederation of Employers and Industries of Spain, October 2012
European Association of Search and Database Publishing, October 2012
Zentralverband der deutschen Werbewirtschaft, October 2012
Germany's advertising industry umbrella ogranisation (ZAW) makes several points which aim at weakening of some provisions. Some of these are:
- Pseudonymized and anonymized data should be excluded from the scope of the Regulation.
- More flexibility when it comes to sharing data with third parties.
- Pseudomised and anonimised advertising targeting must be an exception.
- Leave room for self-regulation.
Handelsverband Deutschland, October 2012
Insurance Europe, September 2012
EuroCommerce, September 2012
Luxembourg Business Federation, July 2012
The German Federal Bar, June 2012
The Bundesrechtsanwaltskammer welcomes the new legislation but wants to make sure that it doesn't interfere in their work. Lawyers collect clients' data as a part of their everyday work. The secrecy obligation must be given precedence over any data protection regulations. The state must not have access or regulate the lawyer-client communication. The German Federal Bar proposes a few ammednment changes which explicitly add lawyer-client scenarios to the exceptions where consent does not have to be confirmed, since the subject is very well aware of the data colleciton in such situations. It advocates that sectoral supervisory bodies should be allowed alongside or instead of territorial data protection control bodies. Lastly the Bunderechtsanwaltskammer want to add a sentence to Article 51: „The supervisory authority shall not be competent to supervise processing operations of courts acting in their judicial capacity” should according to the document be supplemented by „The same shall apply to the activities of lawyers”.
Digital Europe, March 2012
Digital Europe is the lobbying association of European technology producers. In their position paper (Note: see also their proposed ammendments further above.) they claim to welcome strong water protection but advocate less paperwork and hence less regulation. Some of their main points include that privace by design creates unnecessary bureaucratic costs, that the 24 hour data breach notification is similarly too costly to achieve and that administrative sanction create uncertainty and thus harm the industry. Further Digital Europe thnks that the proposed definiton of personal data is too broad and that explicit consent is in many cases non-essential and even a big obstacle. The Commission and the DPA should not be granted any extra powers.
Telefonica, December 2012
British Telecom, December 2012
Nokia, November 2012
eBay, January 2013
Facebook, March 2012
Facebook, January 2013
eBay, December 2012
eBay, November 2012
Amazon, November 2012
Opower, October 2012
Source: https://dataskydd.net/lobbydokument-i-parlamentet-om-dataskydd/ (Swedish)