“How to master Europe’s digital infrastructure needs?” – EuroISPA’s feedback to the European Commission’s White Paper

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The European Commission’s White Paper “How to master Europe’s digital infrastructure needs?” analyses the multiple challenges Europe currently faces in the rollout of future connectivity networks. It presents possible scenarios going forward to address those challenges, attract investment, foster innovation, increase security and achieve a true Digital Single Market.

EuroISPA responded to the European Commission’s public consultation on the White Paper in the name of European Internet Services Providers (ISPs).

Here is a summary of our feedback:

  • EuroISPA welcomes the fact that the Commission highlights the critical importance of ISPs for the future of the EU and draws some meaningful scenarios in order to promote connectivity and simplify and harmonise regulations, which is needed to overcome the challenges ahead.
  • However, EuroISPA finds that many proposals require more clarification from the European Commission and need to take account of national specificities / efficient frameworks.
  • EuroISPA also commends the willingness of the EC to address the sustainability and security of networks, which are essential to ensuring a resilient and sustainable Europe.
Find our full feedback here

EuroISPA publishes Position Paper on Data Retention

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Data retention frameworks refer to the regulation of what data should be stored or archived, where that should happen, and for exactly how long. The obligation of data storage stems from the possibility of law enforcement authorities to request such data to Electronics Communications Services Providers at any time.

In light of the current discussions within the High-Level Group on access to data for effective law enforcement, EuroISPA has published this Position Paper on Data Retention. This paper is a testament to EuroISPA’s collective dedication to identifying the practical, operational and economic consequences and challenges of data retention at both the national and cross-border level.

Allowing law enforcement authorities to prevent and prosecute serious crimes needs while safeguarding the fundamental rights of users and electronic communications services providers is not an easy task, as shown by several rulings of the Court of Justice of the EU. EuroISPA has put together a list of imperative requirements to provide guidance on how to achieve the right balance between the interests and obligations of all parties involved.

EuroISPA, a pan-European association which represents over 3,300 Internet Services Providers (ISPs), works to advocate for the needs both of the wider industry and of users. This position paper is one example of how the association’s members work together to draft recommendations for EU policy makers that can be implemented by the industry in order to tackle the issue at hand.

Read the paper

EuroISPA General Meeting in London: a recap

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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 Süme (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 (FFTélécoms).

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.
Vanessa Franssen
Vanessa Franssen
Vanessa Franssen
Chris Oldknow
Chris Oldknow
Chris Oldknow

EuroISPA publishes Position Paper on Artificial Intelligence

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In the wake of the approval of the Artificial Intelligence Act (EU AI Act) by the European Parliament, EuroISPA publishes its Position Paper on Artificial Intelligence. This paper is a testament to EuroISPA’s collective dedication to shaping a future where AI serves as a force for good, and highlights principles that should be considered for current and future regulatory frameworks on AI, including by the European Union.

EuroISPA, a pan-European association which represents over 3,300 Internet Services Providers (ISPs), works to advocate for the needs both of the wider industry and of users. This position paper is one example of how the association’s members work together to draft recommendations for EU policy makers that can be implemented by the industry in order to tackle the issue at hand. This paper reflects our commitment to establishing a harmonised and globally accepted framework that encourages innovation, upholds ethical standards, and mitigates potential risks associated with AI deployment.

Read the paper

EuroISPA and other tech trade associations and NGOs jointly call on policymakers for a swift adoption of the ePrivacy derogation extension

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Brussels, 23 January 2024 – EuroISPA, together with CCIA Europe and DOT Europe, coordinated the discussions among a coalition of more than 50 tech trade associations and organisations defending children rights on the proposal laying down rules to prevent and combat child sexual abuse.

All signatories share the same goal, which is to create and maintain a safe online environment for children, to detect and remove child sexual abuse (CSA) content online, and to ensure the investigation of offenders, in a manner that is compatible with privacy and human rights.

EuroISPA is particularly proud to see our members CZ.NIC, FiCom, ISPA Austria and ISPA Belgium as individual signatories of the statement, underlining the great commitment of European Internet Services Providers (ISPs) to eradicating online child sexual abuse.

Together, we have agreed to jointly call for a swift adoption of the ePrivacy derogation extension. Below are the main points of our joint call:

  • In the absence of an agreement on the CSA Regulation and the soon-approaching sunset clause of the temporary ePrivacy Derogation, there is a high risk of a legal gap which would prevent interpersonal communications service providers from carrying out selected detection, reporting and removal work against child sexual abuse online.
  • Proactive work against CSA has proven to be effective over the past decade. We therefore ask the European Parliament to support the Commission and the Council on this initiative and call on co-legislators to swiftly adopt the extension of the temporary ePrivacy derogation.
  • We note however that this extension should only be considered as a transitory solution, as the core focus is to agree on a long-term framework, and promptly adopt the CSA Regulation. 

All signatories remain committed to working towards legislation which stands the test of time and that is in the best interest of children.

Read our joint statement

Signatories: 5Rights Foundation, Agarrados à Net, ARSIS – Association for the Social Support of Youth, Asociația Eliberare, Association Novi Put, Brave Movement, Canadian Centre for Child Protection, Center for Missing and Exploited Children (Centar za nestalu i zlostavljanu decu), COFACE – Families Europe, Computer & Communications Industry Association (CCIA Europe), CZ.NIC (Czech Internet Association), Defence for Children International Nederland – ECPAT Nederland, Developers Alliance, Digital Poland Association (Związek Cyfrowa Polska), DOT Europe, ECPAT Albania, ECPAT Austria, ECPAT Belgium, ECPAT France, ECPAT International, ECPAT Luxembourg, ECPAT Norway, ECPAT Sweden, Eurochild, EuroISPA (European Internet Services Providers Association), FAPMI-ECPAT Spain (Federación de Asociaciones para la Prevención del Maltrato Infantil), FICE Croatia, FiCom (Finnish Federation for Communications and Teleinformatics), Fundacja Dajemy Dzieciom Siłę (Empowering Children Foundation), GSMA, Hintalovon Child Rights Foundation – ECPAT Hungary, “Hope for Children” – CRC Policy Center, IAC – Instituto de Apoio à Criança, ICMEC – International Centre for Missing & Exploited Children Singapore, Internet Watch Foundation (IWF), ISPA Austria (Internet Service Providers Austria), ISPA Belgium, ITI – The Information Technology Industry Council, Marie Collins Foundation, Missing Children Europe, Miúdos Seguros Na Net, Network for Children’s Rights (NCR) (Δίκτυο για τα Δικαιώματα του Παιδιού), Pomoc Deci, Safe Online, Save the Children Europe, Stiftung Digitale Chancen, Stop Sexting, Suojellaan Lapsia, Protect Children ry, Terre des Hommes Netherlands, The Pancyprian Coordinating Committee for the Protection and Welfare of Children, The Smile of the Child, Video Games Europe and WeProtect Global Alliance

EuroISPA launches its new Manifesto for an innovative and fair European Internet ecosystem ahead of the 2024 European elections

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We are excited to share EuroISPA’s new Manifesto for the 2024 European elections!

Our Manifesto advocates for putting innovation and fairness in the European Internet ecosystem at the core of the next mandate’s policymaking in the digital sphere.

In this manifesto, the result of the shared knowledge and collaborative effort of our wide and varied membership, we ask EU legislators to commit to the joint implementation of actions towards:

  • A fully functioning internal market
  • A long-term vision on privacy online
  • A harmonised European Strategy for Cybersecurity
  • Legislative Coherence for Digital Infrastructure

By focusing on legislative coherence, data protection, cybersecurity, and digital infrastructure, we believe the EU can enhance its competitiveness, safeguard fundamental rights, and unlock the benefits of new technologies.

Read our full manifesto here: EuroISPA Manifesto for the 2024 European elections

READ OUR MANIFESTO
Read the press release

Position Paper on the Proposal for a Regulation laying down rules to prevent and combat child sexual abuse

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14 September 2022 – EuroISPA publishes its Position Paper expressing concerns about the Proposal for a Regulation laying down rules to prevent and combat child sexual abuse. The document highlights risks of inoperability and technical unfeasibility, concerns around compatibility with the GDPR, DSA, ePrivacy Directive, NIS2, and the Open Internet Regulation, as well as emphasising worries about excessive administrative burdens on SMEs.

EuroISPA, a pan-European association which represents over 3,000 Internet Services Providers (ISPs), works to advocate for the needs both of the wider industry and of users. This position paper is one example of how the association’s members work together to draft recommendations for EU policy makers that can be implemented by the industry in order to tackle the issue at hand.  EuroISPA members are at the forefront of the efforts to protect children online and have a longstanding relationship with law enforcement authorities to assist them in the fight against child exploitation.

Download the Position Paper here.

EuroISPA shares its views on the Digital Services Act

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Brussels, 31 March 2021 – EuroISPA publishes its views on the Digital Services Act, reflecting the views of the European Internet industry.

EuroISPA is the voice of the European Internet industry, representing over 2,000 Internet Service Providers across Europe, all along the Internet value chain. As we have been engaging in discussions on intermediary liability and content moderation for over 20 years, EuroISPA is proud to share with the EU institutions and interested stakeholders its position on the Digital Services Act (DSA).

Overall, EuroISPA supports the DSA and its objectives to protect consumers and their fundamental rights online, to foster transparency and accountability of online platforms, and to favour innovation, growth, and competitiveness within the Single Market. In particular, we welcome the European Commission’s decision to adopt an evolutionary approach maintaining the key principles of the E-Commerce Directive, such as the limited exemption from secondary liability, while creating a due diligence framework for intermediary services.

At the same time, EuroISPA believes that several changes would be needed in order to achieve a regulation that truly fosters innovation and growth in the Digital Single Market. Therefore, EuroISPA put forward recommendations on every chapter of the DSA, spanning from the definition of online platforms, to intermediary liability provisions, from the due diligence rules, to the overall governance structure.

You can download our position below:

2103-EuroISPA-DSA-positionDownload

E-Evidence: EuroISPA adopts Position Paper

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Brussels, 3 July 2018-  EuroISPA is the voice of the European Internet industry, representing over 2500 Internet Services Providers from across Europe and all along the Internet value chain.EuroISPA’s members have long worked with judicial authorities in their countries of operation, and thus have valuable insights on the functioning of existing cooperation. Moreover, the overwhelming majority of EuroISPA’s members are SMEs, and as such, face novel challenges from any new legal regime. EuroISPA has long been engaged on the e-evidence file, having been very active in the proposal’s preparatory stages.

EuroISPA has been a longstanding interlocuter in policy discussions on how to improve cooperation procedures, using its representative role at, for example, Europol’s EC3 communications providers advisory group, the European Commission DG JUST/DG HOME taskforce on e-evidence, and the former European Commission expert group on data retention, to advance such discussions.

EuroISPA and its members feel compelled to stress the negative consequences that will arise from any framework that privatises law enforcement and does not provide clear safeguards for ISPs. Furthermore, EuroISPA emphasises the need for SME exemptions to offset the considerable administrative, legal and financial burden incurred by the cooperation set out by the e-evidence proposal.

The position paper in full can be read here: 1806_EuroISPA_e-evidence_position_paper

EuroISPA statement on proposed Directive on Combatting Terrorism

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Brussels – 22 February 2016 : EuroISPA members take the misuse of their services to disseminate radical and terror content very seriously, and strongly support a clear legislative framework through which swift and effective actions can be taken. Indeed, all EuroISPA members – from access providers to platforms – engage in specific cooperation with law enforcement authorities that reflects their technical position in the Internet ecosystem, to keep cyberspace safe while respecting fundamental rights.

To ensure the Directive on Combatting Terrorism provides the tools for ISPs and public authorities to best cooperate in the efforts to effectively tackle illegal terror content online, we would like to highlight:

  • Need for an explicit reference to the E-Commerce Directive: Directive 2000/31/EC enshrines the principles that allow for smooth cooperation between ISPs and public authorities. Indeed, the Directive’s procedural rules define the legal basis by which ISPs and public authorities can jointly tackle illegal content online while safeguarding fundamental rights – the Notice and Takedown mechanism. To ensure the Directive on Combatting Terrorism provides the adequate instruments to facilitate strong and secure public-private cooperation, a reference to Directive 2000/31/EC is essential.
  • Need for standardised procedures of cooperation across Europe: To ensure ISPs can swiftly remove actual illegal terror content, there is a need for standardised notification procedures across Europe. Often notices are incomplete or misleading, slowing down the removal time for illegal content. Moreover, such notices ought to originate from national judicial authorities, given the inevitable divergence in legal standards of alleged terror content across Member States.

The above principles serve as the basis by which terrorism in the online sphere can be meaningfully tackled, while ensuring that the very freedoms at stake in the efforts to combat terrorism are not undermined.

This statement was circulated to leading members of the European Parliament’s Civil Liberties (LIBE) committee. The LIBE committee is currently scrutinising  the proposed Directive.  

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