EuroISPA General Meeting in Rome: a recap

Rome, June 27-28, 2024

Last week, the EuroISPA community travelled to Rome for the second General Meeting of the year, gathering Council and Forum members, Board Officers and Secretariat, kindly hosted by our Italian member AIIP.

This General Meeting came at a turning point in Europe’s political landscape, with the European elections results still fresh, the start of the Hungarian Presidency, and an entire EU agenda still to shape. This is precisely what our members discussed together in the two-day meeting in Rome. The agenda included:

đź“Ś A nice welcome and overview of the work and priorities of AIIP, representing ISPs in Italy

đź“Ś Analysis of the EU Elections results, what they mean for EuroISPA members, and our upcoming engagement efforts

đź“Ś Approval of EuroISPA’s feedback to the European Commission’s White Paper on Digital Infrastructure. You can read our submission here.

đź“Ś Exchange on several EuroISPA statements on topics such as sustainability, GDPR, AI, data retention, CSAM and payments.

Finally, we had the pleasure of welcoming several guest speakers:

  • Vinicio Peluffo, Member of the Italian Chamber of Deputies for the Democratic Party, on how Italy is preparing for challenges stemming from AI
  • Kristian Bartholin, Secretary to the Council of Europe’s Committee on AI, on the expectations on AI governance at a global level after the Framework Convention on Artificial Intelligence and Human Rights, Democracy and the Rule of Law
  • Giuseppe Bianchi, Professor of Telecommunications at the University of Rome Tor Vergata, the role of infrastructure in enhancing the competitiveness of the EU and its Member States
  • Andrea Margheri, Deputy Head of Division, Industrial, technological, research and training programs at the Italian Cybersecurity Agency, on the interplay between AI and cybersecurity and the opportunities and challenges

The next EuroISPA General Meeting will be held in Brussels in September – stay tuned!

EuroISPA General Meeting in London: a recap

London, March 14-15, 2024

EuroISPA travelled to London on March 14-15 for the first General Meeting on 2024, gathering Council and Forum members, Board Officers and Secretariat, kindly hosted by our member LINX.

On the agenda were topics such as the future of GDPR, the state of the CSAM discussions, our work on piracy of live content, implementation at national level of the DSA, e-Evidence and NIS 2, as well as fruitful exchanges on AI and copyright or the new Commission’s White Paper “How to master Europe’s digital infrastructure needs?“.

Participants also had the chance to discuss the state of our growing membership base, our ongoing work for the European elections, positions on different topics, the new Committees structure, and more.

Most notably, the members unanimously endorsed EuroISPA’s first Position Paper on Artificial Intelligence, that marks the first step and sets the tone of EuroISPA’s increasing work on Artificial Intelligence. You can read the paper here.

The General Meeting also brough about some internal changes in the way of working of the Association. EuroISPA’s Committees, the hub of our policy work, have been undergoing some restructuring and the new configuration of the Committees and the appointment of new Committee Chairs was approved by the Members in London:

  • The Online Content Committee covers topics such as online content moderation, DSA, CSAM, and piracy of live content. The Committee Chair is Alex de Joode (AMS-IX)
  • The Data Economy Committee deals with issues such as data protection, emerging tech, AI, and copyright. The Committee Chair is Oliver SĂĽme (eco)
  • The Cybersecurity & Infrastructure Committee covers from infrastructure to connectivity, including a potential Digital Networks Act and cooperation with law enforcement, for example on e-evidence. The Committee Chair is Paul Guinard (FFTĂ©lĂ©coms).

Read more about the work of our Committees here.

Finally, we had the pleasure of welcoming three guest speakers:

  • Professor Vanessa Franssen from the University of Liege to exchange on our work on data retention and the collaboration between service providers and law enforcement authorities in the context of the High Level Group on Law Enforcement Access.
  • Owen Bennett from Ofcom, the UK’s Communications Regulator, on the Online safety Act and Ofcom’s regulatory approach and alignment with the EU’s Digital Services Act.
  • Christopher Oldknow from our Industry Forum member Amazon on copyright, covering key milestones and relevant trends.

A Week of Collaboration and Insights: EuroISPA’s Recent Activities

Brussels, February 1st-2nd, 2024

EuroISPA’s office has been buzzing with activity over the past week. From internal meetings to engaging discussions with members and industry stakeholders, the association has been actively shaping its strategy and addressing crucial issues in the dynamic landscape of the EU Internet industry.

EuroISPA Industry Forum Meeting

For the first time in 2024, EuroISPA held its Industry Forum meeting, where representatives from our Forum companies gathered to provide advisory insights to the Council Members. The agenda delved into pressing policy matters, focusing on the upcoming legislative cycle and plans leading up to the EU elections. The collaborative atmosphere fostered discussions that will play a pivotal role in shaping the work of the association for 2024.


Executive Board Meeting

In the afternoon, the EuroISPA Executive Board met to set the tone for 2024. Officers and the Secretariat discussed the engagement strategy for the EU elections, outlined focus topics, addressed membership trends, and laid the groundwork for the organisation’s initiatives in the coming months.


Meeting on Piracy of Live Content with European Commission and EUIPO

The following day, EuroISPA hosted a meeting with the European Union Intellectual Property Office (EUIPO) and the European Commission on the topic of piracy of live content. Members and representatives from other industry organisations, with whom EuroISPA regularly collaborates, also participated to the comprehensive discussion. The meeting saw the European Commission presenting the proposed Recommendation on piracy of live content and focused on the published KPIs, the data collection templates and the next steps of the monitoring exercise of the Recommendation. EuroISPA is a leading stakeholder on the matter, and the meeting marked a step forward in the longstanding collaboration with the Commission and the EUIPO, which it actively provides with the technical input from its Members.


ISPA Belgium’s New Year event

To round off the week, EuroISPA Executive Board Officers attended ISPA Belgium‘s New Year event. This provided an excellent opportunity to connect with Belgian figures actively involved in digital policy. The evening included a panel discussion on telecommunications and digital policy in the EU, with a focus on the role of Belgium. The exchange of ideas and insights during this event contributed to consolidate EuroISPA’s relationship with our member ISPA Belgium and to provide a broader understanding of regional challenges and opportunities, especially in light of the ongoing Belgian Presidency of the EU Council.


EuroISPA is committed to collaboration and informed policymaking. As we continue to navigate the ever-evolving landscape of the EU Internet industry, these engagements serve as a testament to its dedication to fostering a thriving digital ecosystem in Europe.

EuroISPA is committed to collaboration and informed policymaking. As we continue to navigate the ever-evolving landscape of the EU Internet industry, these engagements serve as a testament to its dedication to fostering a thriving digital ecosystem in Europe.

EuroISPA hosts expert roundtable on privacy and encryption

On Thursday, 23rd of March 2023, EuroISPA hosted an in-person expert roundtable on privacy and encryption, organised in the context of the European Commission’s proposal for a Regulation to prevent and combat child sexual abuse.

The event gathered a distinguished expert panel comprised of Mr Matthew Green, Associate Professor at the Johns Hopkins University and expert on applied cryptography and cryptographic engineering, Ms Arda Gerkens, CEO and founder of EOKM, as well as Ms Ella Jakubowska, Senior Policy Advisor at EDRi.

EuroISPA’s Board member, Thomas Bihlmayer (eco), moderated the discussion and introduced EuroISPA’s views from its position as a constructive contributor to child protection and privacy debates, thanks to its diverse membership (hotlines, ISPs of all sizes, platforms, cloud infrastructure services, etc.) that is at the forefront of the efforts to protect children online.

He highlighted EuroISPA’s commitment with the Commission’s objective to prevent and combat child sexual abuse and noted concerns over several aspects of the proposal. He focused on the operability of the regulation and on the dangers of breaking encryption, which will have a direct impact on the technical Internet infrastructure and impede efforts to create an Internet which enhances trust, user privacy, and freedom of expression.

Professor Matthew Green expressed concerns about the lack of understanding of the technical implications of the Commission’s proposal, and the possible harm that could bring to the security of global communications systems. During his intervention, he stressed the technical limitations of such proposed measures and the issue of over-relying on them, considering encryption is a very young area. For him, the proposal would benefit from an in-depth evaluation by scientists and researchers in Europe, which in his view should be seen as a pre-condition for mandating new technologies. (He shared his intervention in a more extensive version on his blog).

Representing the Dutch hotline, Arda Gerkens highlighted the issues of weakening encryption, compromising the security both for children and adults. She also noted the potential positive points, especially when it comes to the creation of a EU Centre as a centre for knowledge and support in the EU. She further explained how the approach of the Netherlands to fight child sexual abuse is working, noting some of the main elements that could be brought to EU level.

Finally, Ella Jakubowska raised the perspective of civil society. She explained why the proposed measures will lead to unreliable client-side scanning practices, undermining end-to-end encryption and making our devices more vulnerable to attacks from malicious actors, all without addressing the core issues or finding the right solutions to tackle child sexual abuse.

The panel discussion was followed by a Q&A session were participants had the opportunity to exchange about the compatibility of these measures with privacy legislation, the potential for improvement of scanning technologies as well as other solutions to allow fighting child sexual abuse without hindering privacy safeguards and fundamental rights.

This session is one of the different actions that EuroISPA is taking around encryption, privacy and the Commission proposal to fight Child Sexual Abuse Material online.

If you would like to know more about EuroISPA’s work on the topic, you can contact [email protected].

To read our Position Paper on the proposed CSAM Regulation, click on the button below.

Recap of Past Event: The Upcoming DSA Trilogues and the Future of Content Moderation 

On 26 January 2022, EuroISPA presented the sixth and final online event of its DSA in Focus series, kindly sponsored by LINX. This time, the panelists took stock of the discussions the co-legislators had in 2021 and shared insights on what can be expected in the upcoming trilogues. You can revisit the interventions of our speakers here or below. 

The event gathered a distinguished expert panel comprised of Mathieu Weill, Head of the Digital Economy Department at the French Ministry of Economy, Stefano Montanari, Adviser to the Council of Europe Commissioner for Human Rights and Tobias Schmid, Commissioner for European Affairs of the German Media Authorities (DLM) and former Chair of ERGA.  

Alexandra Laffitte, President of EuroISPA, moderated the panel. In her introductory remarks, she commended the progress made by the co-legislators and the preservation of key principles of the E-Commerce Directive in the DSA, such as the limited liability regime and the prohibition of general monitoring obligations.  

Mathieu Weill emphasized that the DSA is a horizontal framework. Besides, he mentioned that the regulatory burden that has been added was proportionate to the size and the type of players. Finally, he stated that the French Presidency will try to advance the mandate of the Council rapidly and that they are very encouraged by the vote in the European Parliament.  

The necessity to assess and adapt the DSA on a regular basis, was highlighted by Stefano Montanari, as the digital world evolves more rapidly than the regulatory one. Moreover, he argued that having strict safeguards and clear limits on the work of trusted flaggers will be needed.  

Finally, from the perspective of a media regulator, Tobias Schmid stressed that the DSA is not very concrete in certain areas and that the trilogues should focus on how to find a balanced system between regulation, co-regulation and self-regulation.  

This session marked the end of our DSA in Focus series, and EuroISPA would like to once again thank all the speakers for sharing their expertise during this series. From discussing the DSA’s liability regime to reflecting on its transparency and reporting obligations, we have covered a variety of topics, and we would like to extend our gratitude to the audiences for the open exchanges. In the coming months, we hope to announce more events on legislative files relevant to European ISPs and other industry stakeholders, so stay tuned!  

Recap of Past Event: Implementation, Extra-Territorial Application and Enforcement

On 2 December 2021, EuroISPA presented the fifth online event of its DSA in Focus series, sponsored by LINX. This time, the event focused on the DSA’s provisions on the country-of-origin principle, extra-territorial jurisdiction and the Digital Services Coordinators. You can revisit the interventions of our speakers here or below.

The event gathered a distinguished expert panel debating the implementation, the extra-territorial application and the enforcement of the DSA. It was formed by MichaĹ‚ Pukaluk, Director of the Digital Policy Department in the Office of the Polish Prime Minister, Christian Dawson, Executive Director with the i2Coalition, as well as Malcolm Hutty, Chair of EuroISPA’s Intermediary Liability Committee.

Thomas Bihlmayer, Member of the Board of EuroISPA, moderated the panel. In his introductory remarks, he emphasized EuroISPA’s support for increased harmonisation of procedures to tackle illegal content across the EU, in order to ensure legal certainty for businesses and a safe environment for users online.

MichaĹ‚ Pukaluk mentioned that, while the country-of-origin principle needs to be preserved, it will be important to ensure the involvement of the country of destination in the enforcement. Besides, he stated that during the negotiations in the Council, the basic exemptions for SMEs were maintained. Moreover, he expressed his satisfaction with the fact that the DSA is ensuring that illegal content is treated equally offline and online.

Christian Dawson pointed out the dangers of web blocking imposed on Internet infrastructure. He reminded that the Internet infrastructure is mostly formed by small companies, which drive the economy, and which are struggling with burdensome regulatory requirements, such as the ones imposed by the GDPR. 

Malcolm Hutty stated that EuroISPA is supportive of the Commission’s attempt to balance the text and welcomes its broad, cross-cutting and horizontal perspective. Besides, he argued that the country-of-origin principle needs to be respected to ensure EU principles.

EuroISPA wishes to extend its gratitude to the speakers for sharing their knowledge on the new DSA regime and for the open exchange with the audience. We are looking forward to our final event, taking place on Wednesday, 26 January 2022, wrapping up the series.

DSA in Focus: Implementation, Extra-territorial application and Enforcement

Join EuroISPA for our upcoming “DSA in Focus” online panel discussion, entitled Implementation, extra-territorial application and enforcement of the DSA. The event will take place on Thursday, 2 December from 17:00 to 18:30 CET. This is the fifth in a series of six events running until January 2022, in which we will be exploring and debating the main aspects of the Digital Services Act with policy experts. To secure a spot, please register here.

After our first four events, which focused on topics such as notice and action procedures, reporting obligations and transparency, as well as liability of intermediaries, our fifth panel discussion will focus on how to correctly implement the DSA.

Our panellists will address the DSA’s provisions on the Country of Origin principle, extra-territorial jurisdiction, as well as on the Digital Services Coordinators.

As we come closer to interinstitutional negotiations on the dossier, this event will provide an opportunity for an exchange of ideas between policymakers, civil society, and industry representatives.

Programme:

  • Introductory remarks and moderation: Ms Alexandra Laffitte, President of EuroISPA
  • Round-table discussion with:
    • Mr MichaĹ‚ Pukaluk, Director of Digital Policy Department in the Office of the Polish Prime Minister
    • Mr Christian Dawson, Board of Directors Member, i2Coalition
    • Mr Malcolm Hutty, Chair of EuroISPA’s Intermediary Liability Committee
  • Q&A with audience
  • Closing remarks

Secure a spot here!

The “DSA in focus” series kicked off with a first session on the new notice and action regime, followed by a second session on measures going beyond content removal, a third session on reporting obligations and transparency and a fourth one on liability of intermediaries. To end the series, we will host a wrap-up event in January 2022. Don’t miss it! More information is available on our dedicated website page.

Recap of Past Event: Liability of Intermediaries

On 29 September 2021, EuroISPA presented the fourth online event of its DSA in Focus series, sponsored by LINX. This time, the event focused on the DSA articles on the limited exemption from secondary liability for intermediary services, due diligence, own-initiative investigations and general monitoring provisions. You can revisit the interventions of our speakers here or below.

The event gathered a distinguished expert panel debating the objectives of these measures, the practical challenges for implementation and possible ways forward. It was formed by MEP Patrick Breyer, Rapporteur for the LIBE Opinion on the DSA, Dr. Christina Angelopoulos, Lecturer in Intellectual Property Law at the University of Cambridge, Catherine Garcia-van Hoogstraten, Director Responsible Technology Policy, EU Government Affairs at Microsoft, as well as Malcolm Hutty, Chair of EuroISPA’s Intermediary Liability Committee.

EuroISPA’s President, Alexandra Laffitte, moderated the panel. In her introductory remarks, she emphasized that EuroISPA has been advocating for over 20 years in favour of the limited exemption from secondary liability established in the E-Commerce Directive.

MEP Patrick Breyer shared his opinion on the European Commission’s proposal on the DSA, providing for a limited exemption from secondary liability for mere conduit, caching, and hosting service providers. He argued that there is consensus that these provisions are working well and adding new categories would constitute a risk. Moreover, with regards to the own-initiative investigations of intermediaries, he stressed that law enforcement should be kept in the hands of judicial independent authorities, rather than private actors.

Dr. Christina Angelopoulos agreed with MEP Patrick Breyer and insisted that intermediaries are not duty bearers. Besides, she stated that the European Parliament should not move away from the horizontal approach of the European Commission on sector-specific legislation.

Catherine Garcia-van Hoogstraten argued that online service providers should be able to proactively take down illegal content with appropriate tools. Besides, she agreed with preserving the current categorization of the European Commission’s proposal on the DSA.

Malcolm Hutty also welcomed the horizontal approach of the European Commission. Commenting on amendments which created primary liability for intermediaries, he pointed out that this would be unproportionate and lead to over removal of legitimate content. Furthermore, he stressed the need for strict rules against requiring general monitoring.

The panel discussion was followed by an open Q&A session, where participants had the opportunity to exchange with our speakers on these issues.

EuroISPA wishes to extend its gratitude to the speakers for sharing their knowledge on the new DSA regime and for the open exchange with the audience. We are looking forward to our fifth event, taking place by the end of October, which will focus on the implementation, the extraterritorial effect, and enforcement of the DSA.

DSA in Focus: Liability of Intermediaries

Join EuroISPA for our upcoming “DSA in Focus” online panel discussion, entitled Liability of intermediaries, on Wednesday 29 September 2021 at 16:00-17:30 CEST. This is the fourth in a series of six events running until the end of 2021, in which we will be exploring and debating the main aspects of the Digital Services Act with policy experts. To secure a spot, please register here.

After our three first events, which focused on notice and action procedures, measures going beyond content removal and reporting obligations and transparency, our fourth panel discussion will examine the intermediary liability framework in the DSA.

Our panellists will address the DSA articles on own-initiative investigations, limited liability, no general monitoring, etc. They will debate the objectives of these measures, practical challenges for implementation, and possible ways forward.

As the EU co-legislators are intensifying discussions on the DSA, this event will provide an opportunity for an exchange of ideas between policymakers, civil society, and industry representatives.

Programme:

  • Introductory remarks and moderation: Ms Alexandra Laffitte, President of EuroISPA
  • Round-table discussion with:
    • MEP Patrick Breyer, Rapporteur for the LIBE Opinion on the DSA
    • Ms Christina Angelopoulos, Lecturer in Intellectual Property Law at the University of Cambridge
    • Mr Malcolm Hutty, Chair of EuroISPA’s Intermediary Liability Committee
    • Industry speaker (TBC) 
  • Q&A with audience
  • Closing remarks

Don’t miss out, secure a spot here!

The “DSA in focus” series kicked off with a first session on the new notice and action regime, followed by a second session on measures going beyond content removal and, a third one on Reporting obligations and transparency. To end the series, we will host two further sessions in October and November. Don’t miss them! More information is available on our dedicated website page.

Recap of Past Event: Reporting Obligations and Transparency

On 9 September 2021, EuroISPA presented the third online event of its DSA in Focus series, sponsored by LINX. This time, the event focused on the transparency requirements for intermediaries, online platforms and VLOPs, as well as on the issue of access to data, statements of reasons, vetted researchers and access to data, etc. You can revisit the interventions of our speakers here or below.

The expert panel was formed by:  

  • Irene Roche Laguna, Deputy Head of Unit, E-Commerce and Platforms at DG CNECT;  
  • Michal Feix, Senior Public Affairs Advisor to Seznam.cz; and  
  • Diego Naranjo, Head of Policy of EDRi.  

EuroISPA’s President, Alexandra Laffitte, moderated the panel after sharing introductory remarks, highlighting the role of EuroISPA as a strong proponent of transparency obligations for intermediaries which strike the right balance between the competing interests of Governments, users and the protection of companies.  

On the European Commission’s side, Irene Roche Laguna stressed that transparency is the true spirit of the DSA but that it must work in both ways: with a framework for users and authorities to understand why platforms and ISPs take certain decisions and for regulators to report on their activity. She also agreed on the need for grading the access to information depending on the nature of the risks.  

Michal Feix highlighted the importance for the DSA to build on the principles of the e-commerce Directive that have withstood the passing of time but also to consider the differences between, e.g., platforms and other services or recommender systems and advertising, when introducing new rules. In this regard, he noted it is crucial to have limits to transparency requirements in order to maintain the quality of the services they provide. Finally, when touching upon the issue of the statements of reasons, he warned the obligation to anonymize and publish all the decisions would particularly impact companies of the size of Seznam, as they will have to dedicate considerable resources to comply. 

Diego Naranjo emphasized the need for a transparent and balanced notice and action system, that tackles the risks related to the right of removal which would be granted to different stakeholders. He also noted the importance of making algorithms subject to scrutiny by authorities and understandable for users, stating that â€śonline tracking and profiling practices needed to stop”. 

The panel discussion was followed by an open Q&A session, where participants had the opportunity to exchange with our speakers on these issues. 

EuroISPA wishes to extend its thanks to the speakers for sharing their knowledge on the new DSA regime and for the open exchange with the audience. We are looking forward to our fourth event, taking place on 29 September, which will allow our audience to learn about the intermediary liability framework, from own-initiative investigations to the â€śno general monitoring” rule. 

For further information on the upcoming events visit our dedicated webpage on euroispa.org/dsa-in-focus.