EuroISPA’s contribution on Data Retention
EuroISPA contributed to the Call for Evidence of the European Commission on Data Retention.
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EuroISPA’s contribution to the Targeted Public Consultation on the Guidelines for the Protection of Minors under the Digital Services Act (DSA, Article 28)
EuroISPA contributed to the online survey of the European Commission on the guidelines on protection of minors online under the Digital Services Act.
In addition to the answers provided in the online survey of the European Commission, EuroISPA would like to emphasise on the following keypoints:
- The non-binding nature of guidelines: The DSA guidelines should remain advisory and not introduce new legal obligations, ensuring flexibility for platforms to implement tailored, technology-neutral solutions.
- The flexible age assurance methods: Platforms should retain freedom to use a variety of proven age verification tools, including AI and self-declaration, without mandating intrusive or identity-revealing systems.
- The clear boundaries between DSA Articles 28 and 34: Guidelines should avoid overlapping obligations between general safety measures for minors and the specific risk assessments required of Very Large Online Platforms (VLOPs).
- The enhanced minors’ rights in parental controls: Platforms should provide minors with safeguards and complaint mechanisms against misuse of guardian tools, and support account-based parental controls for better, remote, and consistent protection.
- The EU-level parental control framework: A harmonised EU framework for parental control tools is needed to ensure consistency, foster innovation, and avoid market fragmentation across Member States.
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Joint industry statement on the Digital Fairness Act: A call for competitiveness-driven policy
EuroISPA, together with other industry associations, is urging the European Commission to maintain a targeted, evidence-based approach when considering further regulatory interventions; to undergo a thorough assessment of the potential impact on the economy and businesses before introducing further regulatory measures; and to explore alternative avenues, such as improving enforcement of European consumer protection rules.
EuroISPA Contribution to the Recommendation on combating online piracy of sports and other live events
EuroISPA contributed to the Call for Evidence aimed at assessing the Recommendation on combating online piracy of sports and other live events.
Key positions for EuroISPA :
- Expansion of the “Know Your Business Partner” principle
- Caution against the setting up of removal obligations for intermediaries within timeframes that prevent proper examination of disputed content
- Measures against over-blocking as a way of tackling online piracy
- The need to maintain a safe and open Internet
- Cost reimbursements for service providers in burdensome cases
- Implementation of DSA in priority
Read more here.
Joint industry call for Putting Simplification into Action: a Code of Practice for Europe’s AI Continent Ambitions
As the European Commission finalises the Code of Practice for General Purpose AI Models, EuroISPA, together with other industry associations, is calling EU policymakers to uphold the principles of regulatory simplification in the final Code of Practice, by removing unnecessarily complex and burdensome requirements.
A pro-innovation Code will send a strong signal to the EU’s AI ecosystem and to investors and ultimately create the conditions for Europe to truly become the AI Continent.
Joint industry call for allowing the continuation of current Child Sexual Abuse detention practices
Together with other industry associations, EuroISPA is calling on EU Member States to allow the continuation of current Child Sexual Abuse detection practices.
Building on our previous joint statement welcoming the extension of the temporary ePrivacy Directive derogation, we reaffirm that proactive measures against CSA have been instrumental in protecting children online over the past decade.
EuroISPA signs open letter in response to the Going Dark report
As part of our response to the High-Level Group on Access to Data for Effective Law Enforcement (HLG “Going Dark”), and following our reaction to their 42 recommendations, we raise our concerns about the HLG’s final report, together with a broad coalition of civil society groups, industry and professional associations,
As a matter of fact, the group recently presented recommendations that could pose a substantial threat to digital security and privacy for the EU and its citizens.
An EU security policy fit for the digital age must address the challenges we face today. Secure communications and legal certainty are imperative for citizens and law enforcement alike. In the light of potential threats by criminals, foreign state-sponsored agencies and even some authoritarian actors within the EU, people expect the institutions to prioritise policies that protect their IT-security and fundamental rights. That is why we recommend:
- Support a safe, trustworthy and diversified digital ecosystem. Citizens need technology that empowers them instead of putting them at risk.
- Ensure the security and confidentiality of digital spaces because the possibility for people to exercise their fundamental rights depend on it.
- Uphold the right to privacy and inviolability of protected information. This is required by the Charter of Fundamental Rights and case law of the Court of Justice of the EU and the European Court of Human Rights.
Achieving sustainability in Europe’s digital sector
What steps can be taken so that the telecoms sector is a frontrunner in achieving Europe’s sustainability goals? How can we ensure a sustainable and climate neutral digitalisation in Europe?
EuroISPA puts forward 5 key actions to address sustainability challenges for the digital ecosystem and European economy:
- Digital technologies and infrastructures are key to allow the green transition and to achieve greater sustainability.
- More can be done to address sustainability challenges.
- Sustainability should be embedded in the whole digital supply chain.
- Data centres are the cornerstone for untapping the potential of digitalisation to drive decarbonisation.
- Promoting investments of data centres located in the European Union would underpin the greening of the EU economy.
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EuroISPA signs joint industry statement on data processing for AI model training
In a joint statement addressed to the European Data Protection Board (EDPB), EuroISPA and 14 leading European and national trade associations urge the EDPB to adopt a balanced and pragmatic interpretation of GDPR. A thoughtful look into the interplay of the GDPR and the AI Act will be key to make AI “made in Europe” a reality.
EuroISPA reacts to the 42 Recommendations of the High-Level Group on Access to Data for Effective Law Enforcement
EuroISPA welcomes the work and efforts of the European Commission’s High-Level Group (HLG) on access to data for effective law enforcement on promoting a high level of security and an effective approach to fighting
crime and other challenges through the proposed 42 Recommendations.
Earlier this year, the European Commission’s High-Level Group (HLG) on access to data for effective law enforcement out forward 42 recommendations for the further development of EU policies and legislation to enhance and improve access to data for effective law enforcement.
In anticipation of the upcoming discussions of the HLG at the end of the year, EuroISPA would like to take this opportunity to react and give constructive feedback to the recommendations, highlighting some elements that require a careful approach besides further thinking.
EuroISPA welcomes the work and efforts of the Group in promoting a high level of security and an effective approach to fighting crime and other challenges through the proposed 42 Recommendations.
However, EuroISPA is concerned with some proposed recommendations that could weaken encryption, which is a fundamental tool to protect European citizens’ fundamental right to privacy.
Moreover, we underline the need to carefully assess any further measures that can put more burden on European actors, especially the smallest ones.
Finally, any additional measures should take into account the complex value chain that characterises the different ECSs (Electronic Communications Services); any unclear measure might lead to loopholes, further uncertainty when conducting business, as well as threats to the security and the integrity of networks.