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Lobbying Activity

Response to Delegated Regulation on data access provided for in the Digital Services Act

9 Dec 2024

The Association for Computing Machinery (ACM) is the worlds largest and longest established professional society of individuals involved in all aspects of computing. ACMs Europe Technology Policy Committee (Europe TPC) is charged with and committed to providing objective technical information to policy makers and the general public in the service of sound public policymaking. Europe TPC has responded to the European Union (EU) stakeholders consultations in the past in the context of the AI Act, the Data Act, the Digital Services Act, the Digital Citizen Principles, the Cyber Resilience Act, amongst others. ACM and Europe TPC are non-profit, non-political, and non-lobbying organisations. Europe TPC is pleased to provide feedback on the draft Delegated Regulation on data access provided for in the Digital Services Act (DSA) supplementing Regulation (EU) 2022/2065 of the European Parliament and of the Council by laying down the technical conditions and procedures under which providers of Very Large Online Platforms (VLOPs) and of Very Large Online Search Engines (VLOSEs) are to share data pursuant to Article 40 of Regulation (EU) 2022/2065. Europe TPC broadly agrees with the provisions of the regulation set out in the draft act. The procedures and technical conditions appear well-considered and identify the roles and responsibilities of the key stakeholders involved, including the researchers, data providers, and Digital Services Coordinators (DSCs). The time constraints identified for each step of the procedure are likely to play an important role in ensuring that the regulation enables researchers to study systemic risks in the Union and assess the effectiveness of measures to reduce those risks. Europe TPC offers the following recommendations specific to the provisions in the draft act: <ul><li>As part of any publicly accessible interfaces, and the public dashboard provided through the DSA data access portal, the European Commission should aim to ensure wider reach and proliferation of the datasets made available for research, any completed research based on the available datasets, and outcomes relevant to the stated objective of identifying systemic risks to the EU.</li> <li>Objective and consistent criteria should be specified for assessing access modalities, reasoned requests, amendment requests, and granting extensions for duly justified cases to ensure uniform implementation of the draft act across member states, and to enable the DSCs to exercise due discretion in a consistent manner.</li> <li>As part of the reasoned request, the Commission should seek to establish the intent and planned utility of the data access application in clear, research-specific terms, and how it can lead to the identification of systemic risks.</li> <li>Subject to considerations of security, end-user anonymity, and assessments of unforeseen systemic risks to the EU, the Commission should encourage the data providers to grant access to the data in the spirit of open data principles.</li> </ul> The attached document provides additional detailed comments that elaborate on the above recommendations, and are aimed at further strengthening the delegated regulation and enabling robust, rigorous research of high quality and relevance.

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Response to Establishment of the scientific panel of independent experts under the AI Act – implementing regulation

14 Nov 2024

COMMENTS IN RESPONSE TO EUROPEAN COMMISSION CALL FOR EVIDENCE SURVEY ON ARTIFICIAL INTELLIGENCE - IMPLEMENTING REGULATION ESTABLISHING A SCIENTIFIC PANEL OF INDEPENDENT EXPERTS The Association for Computing Machinery (ACM) is the worlds longest established professional society of individuals involved in all aspects of Computing. It annually bestows the ACM A.M. Turing Award, often popularly referred to as the Nobel Prize of Computing. ACMs Europe Technology Policy Committee (Europe TPC) is charged with and committed to providing sound technical information to policy makers and the general public in the service of sound public policymaking. Europe TPC has responded to the European Union stakeholders consultations in the past in the context of the AI Act [1], the Data Act [2], the Digital Services Act [3] [4], the Digital Citizen Principles [5], the Cyber Resilience Act [6], amongst others [7]. ACM and Europe TPC are non-profit, non-political, and non-lobbying organisations. Europe TPC is pleased to respond to the European Commissions call for evidence survey launched on 18 October 2024 on Artificial Intelligence - Implementing Regulation Establishing a Scientific Panel of Independent Experts. Europe TPC supports the European Commissions intent on establishing a scientific panel of independent experts to advise on, and assist the AI Office and national market surveillance authorities with implementing and enforcing the AI Act. Notwithstanding this general support, EuropeTPC would like to raise three recommendations related to the policy paper as currently drafted. The three key recommendations are as follows: 1) The European Commission should outline in more detail the scope of work of the scientific panel before restricting or defining the number of experts, as this would have implications on the total number of experts allocated based on the number of sub-areas, type of engagements, etc. 2) The scope of expertise requested by the panel may require further consideration to go beyond purely technical/scientific expertise. Depending on the respective areas of expertise required, there may be important skills required, such as ethics, law, socio-economic impacts, behavioural sciences, etc. 3) The limit of maximum 3 experts per member state should consider the importance of access to specific and high-demand expertise, which may be available only in certain regions. This is particularly important when considering new AI applications that require nuanced expertise in respective scientific expertise, which may need to take precedence [1] https://www.acm.org/binaries/content/assets/public-policy/europe-tpc-comments-ai-consultation.pdf [2] https://www.acm.org/binaries/content/assets/public-policy/acm-eur-tpc-data-act-comments-13may22a.pdf [3] https://www.acm.org/binaries/content/assets/public-policy/europetpc-digital-services-act-comments.pdf [4] https://www.acm.org/binaries/content/assets/public-policy/acm-europe-tpc-dsa-comments.pdf [5] https://www.acm.org/binaries/content/assets/public-policy/europetpc-comments-digital-principles.pdf [6] https://www.acm.org/binaries/content/assets/public-policy/acm-europe-tpc-cyber-reslience-comments-pdf [7] https://www.acm.org/public-policy/public-policy-statements

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Response to Delegated Regulation on data access provided for in the Digital Services Act

23 May 2023

The Association for Computing Machinery (ACM) is the worlds largest and longest estab-lished professional society of individuals involved in all aspects of computing. It annually bestows the ACM A.M. Turing Award, often popularly referred to as the Nobel Prize of computing. ACMs Europe Technology Policy Committee (Europe TPC) is charged with and committed to providing objective technical information to policy makers and the general public in the service of sound public policymaking. ACM and Europe TPC are non-profit, non-political, and non-lobbying organi¬sa-tions. Europe TPC is pleased to respond to the European Commission call for evidence on Delegated Regulation on data access provided for in the Digital Services Act. As highlighted by the European Commission, online intermediaries (particularly those with millions of users) have become key facilitators of the exchange of information and economic transactions. As such, their actions can have an enormous impact on the safety of citizens or the fairness of businesses commercial activities online. Europe TPC offers the following responses to select Commission inquiries regarding researchers access to data from very large online platforms (VLOPs) and very large online search engines (VLOSEs). Please see the attached for full replies and details. Select Europe TPC points include: Q 1a) -- More than data, metadata, and data governance documentation are needed however, to maximize the transparency and accountability of complex and large-scale algorithmic decision-making systems, particularly those constructed with the aid of machine learning. It is equally important to consider such systems processing architecture and algorithmic components; Q 2a) -- The data researcher vetting process should prioritise the security, privacy and protection of the data made available to researchers. Applicants should be required to certify that they can meet all applicable such requirements once data is made accessible; Q 2b) -- In designing the vetting process, the Commission might consider the United Kingdoms GDS Digital Services Framework for guidance. Q 3b) -- Europe TPC recommends that the Commission create and fund an open consortium with the mission of disseminating best practices for identifying and understanding systemic risks inherent in and associated with the design and operation of VLOPs and VLOSEs. For additional information, or to request the technical advice of ACM and Europe TPC experts, please contact ACM's Director of Global Policy & Public Affairs, Adam Eisgrau, at acmpo@acm.org or +1 202.580.6555.

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Response to Virtual worlds, such as metaverse

3 May 2023

The Association for Computing Machinery (ACM) is the worlds largest and longest established professional society of individuals involved in all aspects of computing. It annually bestows the ACM A.M. Turing Award, often popularly referred to as the Nobel Prize of computing. ACMs Europe Technology Policy Committee (Europe TPC) is charged with and committed to providing objective technical information to policy makers and the general public in the service of sound public policymaking. ACM and Europe TPC are non-profit, non-political, and non-lobbying organizations. Europe TPC is pleased to submit the attached comments in response to the European Commission's consultation on Virtual worlds (metaverses) a vision for openness, safety and respect and its associated Call for Evidence, "EU initiative on virtual worlds: a head start towards the next technological transition." The deployment of virtual worlds accessible to the wider public raises a number of important issues that must be addressed to ensure a fair, safe, and secure environment for users and a competitive environment for economic actors. Europe TPC supports the promotion of an EU virtual ecosystem based on EU values and protection of fundamental rights. Specifically, Europe TPC makes detailed recommendations in the attached with respect to: interoperability; intellectual property protection/content creation; personal data protection, user safety; fair competition/consumer protection; cybersecurity; and environmental impact. ACMs Europe Technology Policy Committee stands ready to leverage the expertise of its thousands of European members to assist the European Commission in its further consideration of these matters, or otherwise with respect to technical matters implicating any aspect of general computing and its societal impacts. To request such technical, apolitical input please contact ACMs Director of Global Policy & Public Affairs, Adam Eisgrau, at acmpo@acm.org.

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Response to Key performance indicators for the Digital Decade policy programme 2030

13 Mar 2023

Capsule Comments (full document attached) The Association for Computing Machinery (ACM) is the worlds largest and longest established professional society of individuals involved in all aspects of computing. It annually bestows the ACM A.M. Turing Award, often popularly referred to as the Nobel Prize of computing. ACMs Europe Technology Policy Committee (Europe TPC) is charged with and committed to provi¬ding objective technical information to policy makers and the general public in the service of sound public policymaking. ACM and Europe TPC are non-profit, non-political, and non-lobbying organizations. Europe TPC is pleased to submit the following comments in response to the European Commission request for feedback on the key performance indicators (KPIs) for the Digital Decade policy programme 2030. Overview Europe TPC generally considers the proposed set of KPIs to be comprehensive and suitable for measuring progress towards achieving the targets established by the 2030 Digital Decade policy programme. We note with some urgency, however, that none of the proposed KPIs address greenhouse gas emissions incident to the deployment of digital technology and strongly recommend that a KPI concerning the measurement of progress towards true reduction of such emissions be added.* Europe TPC also respectfully recommends that this document include one or more statements of the overall goals of the programme, in addition to year over year targets. In the attached, more detailed Comments, Europe TPC also offers specific recommendations with respect to these KPIs: (3) Gigabit connectivity: to provide a more accurate measure of gigabit connectivity the KPIs should consider the number of point-to-point gigabit connections and their actual bandwidth capacity; (7) Quantum Computing: the KPIs should consider and measure the status of European leadership in quantum cloud computing. Additionally, they also need to consider European technical leadership and impact leadership pertaining to hybrid systems. Lastly, this KPI should be modified to focus more generally on quantum technologies and a more precise definition of uniqueness must be developed; (9) Big Data: Europe TPC recommends that the Commission provide a single quantitative definition of big data to ensure uniformity of measurement across the EU Member States; and (10) Artificial Intelligence: Europe TPC recommends measuring usage of high-risk AI applications as defined in the proposed European Union's Artificial Intelligence Act. ACMs Europe Technology Policy Committee stands ready to leverage the expertise of its thousands of European members to assist the European Commission in its further consideration of the Digital Decade policy programme 2030 in this proceeding, or otherwise with respect to technical matters implicating any aspect of general computing and its societal impacts. To request such technical, apolitical input please contact ACMs Director of Global Policy & Public Affairs, Adam Eisgrau, at acmpo@acm.org or +1 202.580.6555. __________ * This request is consistent with Europe TPC's Comments on Draft Decision on Establishing 2030 Policy Programme Path to the Digital Decade of December 10, 2021: "Climate Change: While understandably appealing, reliance on new technologies to accomplish the Commissions climate change mitigation goals actually could be counterproductive. For example, while blockchain technologys functionality may be well suited to the secure operation of global carbon offset markets, its present enormous power consumption needs may negate any emission reductions it fosters. Also see the recent ACM TechBrief on Computing and Climate Change for more background and detail [https://dl.acm.org/doi/pdf/10.1145/3483410]."

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Response to Cyber Resilience Act

23 Jan 2023

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Response to Implementing act on a list of High-Value Datasets

21 Jun 2022

The Association for Computing Machinery (ACM) is the world’s largest and longest established professional society of individuals involved in all aspects of computing. ACM’s Europe Technology Policy Committee (“Europe TPC”) is charged with and committed to providing objective technical information to policy makers and the general public in the service of sound public policy-making. ACM and Europe TPC are non-profit, non-political, and non-lobbying organizations. Europe TPC is pleased to submit the following Comments: Capsule Conclusion and Recommendation While established “FAIR” principles are used as a structure to define open access in the Com-mission’s policy Directive (EU) 2019/1024 on open data and the re-use of public sector information, key aspects of these principles are missing from the proposed implementing Act, particularly provisions addressing challenges to the findability and accessibility of data. Europe TPC respectfully recommends that this omission be addressed in the final proposed Act. Europe TPC also notes that the Commission recognizes that adherence to FAIR principles alone will not by itself assure that critical data sets will be truly “open” in all manners intended and appropriate. We therefore also urge the Commission to clarify to what extent FAIR principles must be applied in this context. “FAIR” Analysis and Application Findability The final Act should require that data and metadata be assigned a globally unique and consistent identifier, such as a Digital Object Identifier (DOI), Universal Resource Name (URN), or Archival Resource Key (ARK). The findability principle also requires that data and metadata be appropriately indexed, allowing potential users to find datasets using meaningful queries. The requirements for a globally unique and consistent identifier, along with existing recommendations for rich metadata within the Act and Annex, will improve the findability of datasets made available under this policy. Requiring that all datasets be indexed by an appropriate platform also should be codified. Accessibility The accessibility of open data depends not only on using recognised open and machine-readable formats, but also requires rigorous archiving practices to ensure its long-term availability. The Act makes clear requirements for formats and application processing interfaces but does not impose any clear requirements on long term archiving practices. Preservation services like CLOCKSS and Portico ensure digital archives are protected against loss in the event that the original publishing organisation fails to preserve digital content. At a minimum, FAIR principles encourage that metadata remain consistently available even if the original data can no longer be archived. The proposed Act should fully reflect this principle. Interoperability Interoperability is discussed in the preamble of the Act in the context of directives relating to specific areas, such as spatial data, but the Act and its appendices do not address this issue explicitly. They should do so as appropriate standards are critical to ensuring interoperability. Reusability The goal of the FAIR principles is to optimize the reuse of data. To achieve this: 1) metadata and data should be described precisely so that they can be replicated and/or combined in different environments; and 2) provenance of the data, a key issue in assuring data reusability, should be made a clear requirement for metadata in the Act’s Annex. Conclusion ACM’s Europe Technology Policy Committee stands ready to leverage the expertise of its thousands of European members to assist the European Commission in its further consideration of access to high value data sets in this proceeding, or otherwise with respect to technical matters implicating any aspect of computing and its societal impacts. To request such technical input please contact ACM’s Director of Global Policy & Public Affairs, Adam Eisgrau, at acmpo@acm.org or +1 202.580.6555

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Response to Data Act (including the review of the Directive 96/9/EC on the legal protection of databases)

13 May 2022

SECOND FILING: REPLACES ORIGINAL CORRUPTED AND UNREADABLE PDF COMMENTS ATTACHED The Association for Computing Machinery (ACM) is the world’s largest and longest established professional society of individuals involved in all aspects of computing. It annually bestows the ACM A.M. Turing Award, often popularly referred to as the “Nobel Prize of computing.” ACM’s Europe Technology Policy Committee (“Europe TPC”) is charged with and committed to providing objective technical information to policy makers and the general public in the service of sound public policymaking. ACM and Europe TPC are non-profit, non-political, and non-lobbying organisations. Europe TPC is pleased to submit the following Comments in response to the Commission’s above-captioned consultation on the “Data Act,” opened on 23 February 2022. Key Recommendations are summarized here and detailed in the attached PDF Comments. To access the non-lobbying technical expertise of ACM and Europe TPC's members, please contact ACM's Director of Global Policy & Public Affairs, Adam Eisgrau, at eisgrau@acm.org: Key Recommendations 1. The scope of the Data Act should be expanded to encompass metadata when it is needed to permit reasonable consumption and processing of underlying data by processing services. (Articles 2, 3) 2. The Data Act must be formulated to define, address, and preclude or minimise foreseeable environmental impacts, including particularly those associated with smart contracts and distributed ledger-based technologies. (Articles 11, 30) 3. Requirements imposed by the Data Act on the acquisition and processing of data should be carefully assessed and drafted to assure that they do not unnecessarily add to the complexity and cost of those activities. (Articles 5, 8, 11, 15, 23, 24, 26, 30)

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Response to European chips act package – Regulation

9 May 2022

The Association for Computing Machinery (ACM) is the world’s largest and longest established professional society of individuals involved in all aspects of computing. It annually bestows the ACM A.M. Turing Award, often popularly referred to as the “Nobel Prize of computing.” ACM’s Europe Technology Policy Committee (Europe TPC) is charged with and committed to providing objective technical information to policy makers and the general public in the service of sound public policymaking. ACM and Europe TPC are non-profit, non-political, and non-lobbying organizations. Europe TPC is pleased to submit the following Comments in response to the Commission’s above-captioned consultation on the proposed Chips Act, opened on 8 February 2022. For further information, or to request the technical assistance of ACM's European experts, please contact: Adam Eisgrau ACM Director of Global Policy & Public Affairs eisgrau@acm.org +1 202.215.6884

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Response to Policy Program - Digital Decade Compass

10 Dec 2021

The Europe Technology Policy Committee (“Europe TPC”) of the Association for Computing Machinery (ACM) is pleased to offer the attached Comments on the Commission's Proposal for a Decision on Establishing the 2030 Policy Programme “Path To The Digital Decade.” ACM is the world’s largest and longest established professional society of individuals involved in all aspects of computing. It annually bestows the ACM A.M. Turing Award, often popularly referred to as the “Nobel Prize of computing.” The ACM Europe Technology Policy Committee is charged with and committed to providing objective technical information to policy makers and the general public in the service of sound public policymaking. ACM and Europe TPC are non-profit, non-political, and non-lobbying organizations. See, https://europe.acm.org/europe-tpc. ACM, Europe TPC, and their thousands of expert European members stand ready to assist the Commission at any point in its further consideration of the Draft Decision or otherwise with respect to technical matters implicating all aspects of computing. To request such technical, apolitical, and non-lobbying input, please contact ACM’s Director of Global Policy & Public Affairs, Adam Eisgrau, at acmpo@acm.org or +1 202.580.6555. Transparency Register ID No.: 133002517679-87

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Response to Requirements for Artificial Intelligence

5 Aug 2021

HIGHLIGHTS OF COMMENTS BY THE EUROPE TECHNOLOGY POLICY COMMITTEE OF THE ASSOCIATION FOR COMPUTING MACHINERY * (PLEASE SEE ATTACHED DOCUMENT FOR EUROPE TPC'S FULL ANALYSIS OF THE PROPOSAL) The Association for Computing Machinery (ACM) is the world’s largest and longest established professional society of individuals involved in all aspects of computing. It annually bestows the ACM A.M. Turing Award, often popularly referred to as the “Nobel Prize of computing.” ACM’s Europe Technology Policy Committee (“Europe TPC”) is charged with and committed to providing objective technical information to policy makers and the general public in the service of sound public policy formation. ACM and Europe TPC are non-profit, non-political, and non-lobbying organizations. Europe TPC is pleased to provide the following “feedback,” as invited by the European Commission, on the pending Proposal for a Regulation of the European Parliament and of the Council Laying Down Harmonised Rules on Artificial Intelligence (Proposal). GENERAL OBSERVATIONS Europe TPC supports the intent of the proposed AI Regulation to set harmonised rules for the development, placement on the market, and use of AI systems in the European Union following a proportionate risk-based approach that would most regulate the use of AI systems which pose significant risks to the health, safety, or fundamental rights of individuals. The Proposal, however, raises several significant technical concerns detailed below as “Specific Comments.” Europe TPC first wishes to highlight in broad terms that: 1. The Proposal’s definition of high-risk systems would benefit from a more precise definition of the risk hierarchy (see discussion of Articles 6 and 7); 2. The proposed regulation incorporates technical computer science and mathematical terms without formally defining them. Such imprecision may lead to counterproductive ambiguity in their interpretation and inconsistency in their application. In addition, the Proposal’s treatment of “health and safety” issues is generic rather than based, as would be advisable, on the highly evolved technical discipline of Safety Assurance (see discussion of Article 15); 3. Final regulations to be adopted by the co-legislators must in multiple ways fully respect personal privacy, affording at minimum the full protections mandated by all other applicable current law or regulation (including the General Data Protection Regulation). Protections afforded by the Proposal also must, in Europe TPC’s view, expressly include constraints on continuous data collection in public contexts (see discussion of Article 52); and 4. While constructively calling on all Member States to have a sufficiently large workforce expert in AI and many other related matters, the Proposal does not concretely address or enable the forms of education necessary to create such a highly skilled and appropriately diverse population (see discussion of Article 59). CONTACT: ACMPO@ACM.ORG _____________ * Principal authors of this document for ACM’s Europe Technology Policy Committee are: Alejandro Saucedo, Engineering Director at Seldon Technologies and Chief Scientist at Institute for Ethical AI & Machine Learning; and Chris Hankin, Fellow of the Institute for Security Science and Technology and Professor of Computing Science at Imperial College, London. Also contributing were: Oliver Grau, Principal Investigator at Intel Corporation; Dame Wendy Hall, Regius Professor of Computer Science, University of Southampton; Andrew McGettrick, Professor Emeritus of Computer and Information Sciences, University of Strathclyde; Enrico Nardelli, Professor in Informatics at Università di Roma; Gerhard Schimpf, Senior Manager at SMF Management Consulting - Pforzheim; Gurkan Solmaz, Senior Researcher at NEC Laboratories Europe; and Julie Williamson, Lecturer in Human Computer Inter¬action, University of Glasgow. (NOTE: All affiliations listed for identification purposes only.)

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Response to Digital Services Act: deepening the Internal Market and clarifying responsibilities for digital services

31 Mar 2021

COMMENTS OF THE EUROPE TECHNOLOGY POLICY COMMITTEE OF THE ASSOCIATION FOR COMPUTING MACHINERY* ON “THE DIGITAL SERVICES ACT – DEEPENING THE INTERNAL MARKET AND CLARIFYING RESPONSIBILITIES FOR DIGITAL SERVICES” The Association for Computing Machinery (ACM) is the world’s largest and longest established professional society of individuals involved in all aspects of computing. It annually bestows the ACM A.M. Turing Award, often popularly referred to as the “Nobel Prize of computing.” ACM’s Europe Technology Policy Committee (Europe TPC) is charged with and committed to providing technical information to policy makers and the general public in the service of sound public policy formation. ACM and Europe TPC are non-profit and non-lobbying organizations. Europe TPC intends to submit more detailed and potentially broader comments to the Commission ahead of a final determination regarding adoption of the Digital Services Act (DSA) but, for the record in this proceeding, presently wishes to underscore two key points – one general and the other quite specific – on which it anticipates elaborating: • The success of the DSA will depend upon the ability of platforms and other regulated entities to successfully deploy automated content moderation systems. From a technical perspective, while the architecture and application of such systems vary, all have and will continue to have inherent limitations and biases that must be fully understood, and appropriately safeguarded against, in legislation if such systems are to be used to maximum and accurately predictable effect; and • As detailed in Article 31, functioning of the DSA’s proposed regulatory regime will in no small measure depend upon non-governmental technical experts, referred to as “vetted researchers,” for the effective audit of platforms’ and others’ compliance with the Act. Such researchers and the utility of their work, in turn, will be dependent upon access to large data sets sourced from regulated platforms. As ultimately drafted, however, large numbers of otherwise qualified researchers should not inadvertently or by design be prevented from qualifying as “vetted researchers” by overly restrictive or imprecisely drafted provisions governing the secure storage of platform data received. Europe TPC and the experts of the ACM Europe Council stand ready to assist the European Commission as negotiations on the DSA continue, both by consulting transparently and informally on technical matters as the process advances and in Europe TPC’s more detailed submission to come. For such assistance, please contact Chris Hankin, Chair of Europe TPC, at c.hankin@imperial.ac.uk and Adam Eisgrau, ACM’s Director of Global Policy & Public Affairs, at eisgrau@acm.org. ______________________________________ * Europe TPC’s work is further described in the Commission’s Transparency Register under “ACM-Europe” (Identification Number: 133002517679-87).

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Response to Legislative framework for the governance of common European data spaces

23 Jul 2020

I am writing on behalf of the ACM Europe Technology Policy Committee; the Association for Computing Machinery (ACM) is the world's largest computer society with about 100,000 members worldwide and about 18,000 members in Europe. We strongly support the objectives stated in Section B of the Inception Impact Assessment. At this point in time, we particularly support the sharing of best practices between Member States and the development of a common European consent form and associated, certified tools to help foster data altruism. The ACM Europe Technology Policy Committee stands ready to engage with the European Commission on the further development of this important area. Our interventions to date have focused on algorithmic issues, including a statement on algorithmic transparency and accountability (to be found at https://www.acm.org/binaries/content/assets/public-policy/2017_joint_statement_algorithms.pdf) and a white paper on algorithmic decision making (to be found at https://www.acm.org/binaries/content/assets/public-policy/ie-euacm-adm-report-2018.pdf).

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