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Asociación Española de la Economía Digital

Adigital

Asociación empresarial que representa a más de 400 empresas, con el objetivo de impulsar y promover el comercio electrónico, el desarrollo de Internet y de la Sociedad de la Información y los modelos de negocio online.

Lobbying Activity

Response to Consumer Credit Agreement – review of EU rules

2 Sept 2021

The European Commission recently published a new proposal for a Directive on consumer credits repealing and replacing the existing Consumer Credit Directive (2008/48/EC). With the proposal, the Commission aims to increase consumer protection for consumer credits. The Commission recognises that consumer credits help consumers finance all sorts of projects and goods. However, it argues that digitalisation has changed the lending sector, and that consequently, new ways of disclosing information digitally and of assessing the creditworthiness of consumers using automated decision-making systems and non-traditional data need to be addressed. Moreover, the Commission also finds that the COVID-19 crisis and the resulting confinement measures have also disrupted the EU economy and had a major impact on the credit market and consumers, making many EU households more financially vulnerable. Adigital welcomes the opportunity to share its position with the European Commission and the following document presents its input to the proposal for a Directive on consumer credits open feedback period.
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Response to Requirements for Artificial Intelligence

3 Aug 2021

Please find attached Adigital´s contribution to the European Commission´s proposal on the Artificial Intelligence Act
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Response to Digital Services Act package: ex ante regulatory instrument of very large online platforms acting as gatekeepers

5 May 2021

Adigital shares the objective of the markets remaining fair and contestable for innovators, business and market entrants, and understands the final goals of the Digital Markets Act. However, we consider that some elements should be clarified to avoid the possibility of having unintended effects and harmful consequences in the ecosystem both on consumers and business users of platforms. The Digital Markets Act (DMA) is a significant proposal that will sit at the centre of the EU’s regulatory framework for digital markets and technologies. It is an important measure for the EU’s ambitious plans in the digital economy. The DMA represents a novel way of regulating large companies in certain digital activities rather than markets more broadly. This increases the need for clarity, legal certainty, and accountability. In this regard, we welcome the opportunity to contribute constructively to the construction surrounding the EU's legislative proposal of the DMA.
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Response to Digital Services Act: deepening the Internal Market and clarifying responsibilities for digital services

29 Mar 2021

The Commission announced on the Communication on ‘Shaping Europe’s Digital Future’ a Digital Services Act package, including a proposal of new and revised rules to deepen the Single Market for digital services, by increasing and harmonising the responsibilities of online platforms and information society service providers. In December 2020, the European Commission proposed a comprehensive reform of the digital space, a comprehensive set of new rules for all digital services, including social media, online marketplaces, and other online platforms that operate in the European Union: the Digital Services Act and the Digital Markets Act. The Digital Services Act will introduce a series of new, harmonised EU-wide obligations for digital services, carefully graduated on the basis of those services' size and impact. The following document presents the input from Adigital to the Digital Services Act (DSA) open feedback period.
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Response to Revision of the NIS Directive

18 Mar 2021

Please find attached the Spanish Association on the Digital Economy (Adigital) contribution to the consultation on the proposal for a Directive on measures for a high common level of cybersecurity across the Union, repealing Directive (EU) 2016/1148.
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Response to EMAS Sectoral Reference Documents for Telecommunications/ICT services

11 Feb 2021

On 15 January 2021 the European Commission launched for feedback the draft Commission Decision "on a sectoral reference document on best environmental management practices, environmental performance indicators and criteria of excellence for telecommunications and information and communication technology (ICT) services". Adigital welcomes the draft Commission Decision on this key sector. In this regard Adigital would like to make a couple of suggestions over the draft: Firstly, we believe that colocation data centers should be included more specifically in the documente., for example in the scope. The draft lists a lot of types of companies but it misses the ones that host more than 60% of the world's ITC equipment, that is, the colocation data centers. Although the document mentions the datacentres, referring to the physical spaces of these companies, from Adigital's point of view, it would be advisable to include or at least the concept of the "colocation data centres, as exchange points of ICT services''. Secondly, in section 3 on "Best Environmental management practices" we think it would be advisable to add something like: "use as much as possible 100% green energy", as a good practice policy. This would be seen as a good thing, not mandatory, but recommended. Also, if this were the case, it would boost renewable generation.
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Response to Legislative framework for the governance of common European data spaces

8 Feb 2021

Please find attached Adigital contribution to the consultation on the proposal for a Regulation on data governance
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Response to Requirements for Artificial Intelligence

10 Sept 2020

Document attached
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Response to Report on the application of the General Data Protection Regulation

29 Apr 2020

The following document has been elaborated by Adigital, the Spanish Association for the Digital Economy, in view of the European Commission public consultation on the implementation of the General Data Protection Regulation. In particular, Adigital focuses on: (i) international transfers to non- EU countries, and (ii) the cooperation mechanism between national data protection authorities. I. Transfers of personal data to non-EU countries With respect to the international transfers of personal data and the cooperation mechanisms, one of the most disturbing situations to our associates was the fact that we do not have it clear to which National Authority do we have to report to when it comes to data breaches, having into account that there are companies with subsidiaries within many countries. Especially when subsidiaries lack of legal personality and the data breach affects only a certain country. In situations like the aforementioned the GDPR becomes inaccurate as it does not illustrate if the data breach shall be notified to the Authority where the parent company -the controller of the processing- is sited or to the one sited in the specific country where the data breach took place -despite subsidiaries lack of legal personality-. There could be also another possible situation: to inform both Authorities about the data breach suffered. In short, one of the issues Adigital associates have experienced since the GDPR implementation is the absence of guidance in order to make it clear to which specific Authority companies have to report data breaches in conditions like the ones mentioned before. II. Cooperation mechanisms between national data protection authorities Standardization of criteria regarding certain legitimate purposes in the context of those difficulties suffered by insurance multinational companies when applying the GDPR. For instance, in Portugal it is needed the consent of the data subject to process sensible data, where in Ireland it is committed to the performance of the insurance contract.
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Meeting with Manuel Mateo Goyet (Cabinet of Commissioner Mariya Gabriel)

4 Oct 2018 · Digital Skills and DSM