Feedback to the Commission's Proposal on a Framework for the Free Flow of Non-Personal Data

Abstract

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