DIGITALEUROPE response to BEREC data economy consultation

Question 1.1

Do you agree on this general definition of the Data Economy? If you have an alternative definition or any comments on the proposed definition, please provide details below.

DIGITALEUROPE agrees that the general definition of the data economy put forward by the Commission in its 2017 Communication ‘Building a European Data Economy’ is broadly correct. However, we believe that a specific definition might not be needed. Given how pervasive the use of data now is across multiple industry sectors and verticals, it is increasingly less relevant to separate out the data market from ‘the economy’ as a whole.

Question 1.2

In your opinion, what are the most important characteristics of data to be taken into account when analysing its economic properties? Are there elements missing in the previous list?

DIGITALEUROPE agrees both with the above characterisation of data as non-rivalrous and with the four key characteristics that have been outlined. Other important aspects of data that we believe should be taken into account in this discussion are the following:

1. Many types of data are replicable or easily substitutable. Users can provide the same data to more than one service; each service can generate proprietary usage and telemetry data, which can be used to improve the service. Such data generation does not, of itself, prevent a competing service from generating its own similar usage data specific to its service;
2. Seeking a wide variety of data inputs is key to gaining valuable insights, and it is unlikely that a single entity will control all such relevant data; and
3. Not all data is commercially useful. The quality of the data collected and how it is used is as important as the volume. The relevance and importance of any single data set often only become apparent after statistical study. It is often not obvious in advance whether the addition of a given data set will add more predictive ability.

[…]