ICC comments on EU Directive 95/46/EC

‘A comprehensive approach on personal data protection in the European Union’

Our comments go to both the substantive recommendations of the Commission Communication as well as to the illustrative examples used. The comments related to illustrative examples are provided to add further context to issues that are important to consider as the Commission contemplates revisions to the Directive that may impact those examples in deployment. We also believe that this Commission Communication helps shape the context of the policy debate going forward and wanted to ensure that it was as reflective as possible of both the concerns and potential benefits related to new applications of technology and emerging business models. The process related to the review of Directive 95/46/EC is critically important in today’s world of national, regional and global information flows. The Directive and its national implementations form the basis for exchanges of personal data both within the EU region and globally. We thank the Commission for the opportunity to provide these responsive comments and look forward to working constructively with the Commission and the broader stakeholder community in this process.