Comments on selected topics in the draft EU data protection regulation

Korff, Douwe (2012) Comments on selected topics in the draft EU data protection regulation. Other. SSRN.


In January 2012, the European Commission published its proposals for a new EU data protection regime. Not surprisingly, this started extensive debates and lobbying, especially from big industry. The European Digital Rights Initiative, EDRi, hopes to provide comments from the civil society/human rights/digital rights perspective. These comments are being prepared in an EDRi data protection working group. I am am member of that group, and volunteered to provide comments on the topics addressed in this paper. For now, the general consultations and the work of EDRi and this working group is largely confined to issues relating to the centerpiece of the Commission proposals, the Draft EU Data Protection Regulation.

This paper sets out my thinking on my chosen topics, with proposals for specific amendments to the text of the proposed new EU Data Protection Regulation. They are essentially for discussion within the EDRi dp working group, but can also be shared with others. However, I should stress that, for now, the contents of this paper only reflect my own thinking: they do not necessarily reflect the views of EDRi or any of its member organisations. If therefore I have at times (indeed quite often) used “we” in the text, this is merely in anticipation of the text possibly being used by EDRi etc. At other times, when I am clearly referring to my own ideas and work, I have used “I”. I hope this is not too confusing.

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