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Privacy First participation in EU consultation on simplifying digital rules

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Privacy First recently participated in the consultation by the European Commission On the simplification of European digital rules. In our consultation response, Privacy First warns that digitalisation is not only creating positive effects, but also exponentially increasing risks for consumers and small organisations.

On top of that, current European digital rules are insufficiently enforced. In doing so, we refer to a recent report by Interface on child protection[1] and to a 2024 report by European privacy regulators[2] showing that the AVG cannot be enforced on non-EU parties.

Level playing field and enhanced protection for citizens and small organisations

Our response makes a large number of recommendations to strengthen supervision and enforcement, which can also create a level playing field for European companies.

The rules on tracking technologies (cookies, IP address recognition and device recognition and the like) could be simplified by no longer allowing them for public authorities and providers of essential services. Furthermore, we advocate making data trading subject to licensing and quickly identifying the risks AI poses to citizens and small organisations.

European Digital Identity

Privacy First separately addresses the issue of identification and trust services. We explicitly warn against overidentification and suggest, among other things:

  • Prohibit organisations from requiring their counterparties (customers, citizens) to use the European digital identifier on pain of not getting a product or service.
  • Require those using the European digital identifier to demonstrate that the use of the device is voluntary and that the individual understands the risks associated with electronic identification.

These proposals are in line with the request which Privacy First previously made to De Nederlandsche Bank and the Minister of Finance to adjust the identification practices of financial institutions (pdf).

Privacy First's entire consultation submission is here can be found (pdf).[3]

 

[1] Mind the Gap | Age Assurance and the Limits of Enforcement under EU Law, https://www.interface-eu.org/publications/age-assurance-gap .

[2] EDPB: Report on the extraterritorial enforcement of the GDPR.

[3] See also this link To the European Commission's consultation page. (Click on ‘Show original language (NL)’).