DIGITALEUROPE’s comments on the consultation on the regulatory environment for platforms, online intermediaries, data and cloud computing and the collaborative economy – Annex document

INTRODUCTION

DIGITALEUROPE welcomes the opportunity to contribute to the public consultation on the regulatory environment for platforms, online intermediaries, data and cloud computing and the collaborative economy, as we believe that these issues deserve in-depth consultation with all parties involved and analysis before rushing into any legislative action.
However, we would like to outline the difficulties we encountered in trying to respond to the questionnaire built by the European Commission. We regret, for instance, that sections for comments were not made available for every question of the consultation as such availability depended on the answer given – yes or no. This constitutes a missed opportunity for respondents to explain their position as well as for the European Commission to understand the context and the reasons why a specific position is taken. We also regret the phrasing of many questions, for which we see a degree of bias that will result in misleading answers from the respondents. Finally, the questionnaire lists a selection of assumed practices of platforms – Section IV of the first of part of the consultation – out of context and in isolation from each other.

In this regard, we would like to provide some additional comments on the first three sections of the public consultation, which we hope the European Commission will find useful.