In this joint response with our partner organization, the Federation of Business Information Services (FEBIS), ACCIS and FEBIS agree that the European Union needs to strengthen data sharing mechanisms, to increase the availability of data and thus facilitate the creation of new products and services for the benefit of European consumers and businesses. ACCIS and FEBIS welcome the Data Governance Act as we see this initiative as a step in the right direction.
Concerning the definition of intermediation services under Article 9 (1)(a), ACCIS and FEBIS think that it is very broad and may, theoretically, cover almost any facilitation of data exchange between data holders and potential data users. We would recommend that intermediation services are defined more clearly in the articulated text, with basis on the exemptions mentioned in the recitals.
ACCIS and FEBIS support, in particular, that the DGA will open up data held by public sector bodies which is currently unavailable, including for reasons of commercial or statistical confidentiality. The provisions on reuse of “protected” data held by public sector bodies are, however, not ambitious enough. ACCIS and FEBIS think that public sector bodies should be subject to an obligation to open up currently unavailable data. This would create a right for companies to access such data.