Feedback to the Commission's Proposal on a Framework for the Free Flow of Non-Personal Data
6 Pages Posted: 30 Jan 2018
Date Written: January 22, 2018
With this submission, we would like to take the opportunity to submit feedback, in our personal capacity as researchers, to the European Commission’s Proposal on a framework for the free flow of non-personal data in the European Union (‘the proposal’).
Our submission aims to raise two main concerns:
• the indeterminate and dynamic nature of the notion of ‘non-personal data’ as a starting point for legislation; and
• the occurrence of possible clashes with the General Data Protection Regulation (‘GDPR’) and the fundamental right to data protection.
Keywords: concept of personal data; identifiability; free flow of data; data economy; data portability
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