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CIO Platform Nederland

CIOPN

CIO Platform Nederland is the Dutch association of business users of digital technologies.

Lobbying Activity

Response to Digital package – digital omnibus

14 Oct 2025

CIO Platform Nederland (CIOPN) supports the Commissions objective to simplify the diverse set of rules on data, AI and cybersecurity that have been published in recent years. It is necessary to regulate European digital societies and markets, however there is a delicate balance to be struck to ensure that regulation is not overly burdensome due to overlaps and conflicts between the different texts. Please find our recommendations and suggestions in the attached file.
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Response to Revision of EU antitrust procedural rules

2 Oct 2025

Attached is the consultation contribution from CIO Platform Nederland, the Dutch association representing business users of digital technologies.
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Response to Review of the Digital Markets Act

23 Sept 2025

With 140+ of the largest Dutch companies, knowledge institutions and government organisations, CIO Platform Nederland (CIOPN) forms the largest Dutch community of business users of digital technology. Digital markets for our members are characterised by the high dependency on a limited number of large technology suppliers, particularly those of non-European origin. The Digital Markets Act (DMA) has a role to play in solving these persistent problems. The attached document introduces and explains the Perspective of Dutch Business users of IT on the functioning and effect of the Digital Markets Act in practice, and presents changes to improve the digital markets in Europe.
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Response to The EU Cybersecurity Act

20 Jun 2025

CIO Platform Nederland welcomes the opportunity to share its insights, and those of the CIO associations in Belgium and Germany, on the Cyber Security Act with the Commission. You can find these in the attached document, which has been drafted in close coordination with Beltug and VOICE e.V. We are off course available to explain our positions to the Commission, should that be desirable.
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Meeting with Werner Stengg (Cabinet of Executive Vice-President Henna Virkkunen)

22 May 2025 · European technological sovereignty

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

8 Feb 2024

CIO Platform Nederland is the association of business users of digital technologies in the Netherlands. By and large we hear from our members the same comments that have been submitted by the French association of business users of digital technologies, Cigref. In addition to their input, we have two observations that are elaborated in attached document. Our primary observation is that there is a serious overestimation of the negotiating power of users of digital technologies vis-à-vis several large providers of technologies that are used to process personal data. This necessitates a carefull and fair redistribution of responsibilities. A second observation relates to the notification of data leaks and how these are treated by DPAs. Going forward we would recommend the GDPR be amended to more fairly distribute responsibility regarding the safe and secure processing of personal data along the value chain. Parties involved should only be made responsible for the compliance with GDPR for the process, product or service settings that they can actually influence. And, secondly, to lessen the burden and risk of notifying data leaks, so such incidents are more readily notified and can lead to more knowledge on how to prevent data leaks.
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Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur)

9 Sept 2022 · AI Act

Meeting with Svenja Hahn (Member of the European Parliament, Shadow rapporteur)

30 Aug 2022 · Artificial Intelligence Act (AIA)

Meeting with Kim Van Sparrentak (Member of the European Parliament)

26 Oct 2021 · Digital Markets Act

Response to Requirements for Artificial Intelligence

5 Aug 2021

CIO Platform Nederland welcomes the opportunity to provide feedback on the proposal for the Artificial Intelligence Regulation. We consider the AI proposal a starting point to assess how to honour fundamental rights, health and security, while allowing AI technology to flourish. In brief, an appropriate framework for the safe, responsible, and sustainable use of AI systems in Europe is essential for the full exploitation of AI technology in the years to come. AI encompasses a very broad range of technologies which develops at a very high rate. For business users, each category of AI has specific opportunities, operational contexts and use cases as well as risks. In particular, we have identified five aspects that we believe require additional attention or should be re-evaluated. Taking into account these aspects would help create an AI-Act that enables business users to effectively contribute to European economy and society by using AI systems. For our full view, please find our position paper below.
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Response to Legislative framework for the governance of common European data spaces

2 Feb 2021

In brief our views, concerns and suggestions are listed below, a more elaborate feedback is available in the uploaded letter. Due to the nature of their work, our members find themselves in a position where data plays a predominant role. Large amounts of data from an ample variety of sources ensures both businesses and organisations can find new opportunities to innovate and develop. Data has become fundamental to large parts of the economy and society, both in the Netherlands and in Europe as a whole. The DGA signals a necessary and relevant development, and we therefore welcome its aim to introduce previously inaccessible data. We believe that the crucial role of data cannot be underestimated. For our members this means that generally speaking more data means more innovation, development and improvement. European initiatives that have as objective to realise the availability of more data are therefore applauded and encouraged. In particular the suggested new sources of dataflows from the public sector are deemed to be very helpful to the work of our members. The data in question is expected to be useful and applicable due to its public and scarce nature. The new accessible dataflows from the public sector can be of real significance to especially academic research and other scientific initiatives. This said, we have to express our members’ concerns about certain aspects of the current proposal. Making public organisations’ information and data more widely accessible is in theory a useful and compelling initiative that will benefit the continent’s economy and society. Yet it is not without its risks. Privacy and security question loom large over the Act in its current form. In order to safeguard European citizens and prevent unintended consequences as a result of the reuse of data, more effort has to be spent on security and privacy. The DGA is regarded as too permissive and not yet sufficiently secure to share and access sensitive data. Furthermore, we anticipate issues concerning the reuse of public sector’s data in combination with the GDPR. Our members are eager to access possible new data, yet would prefer a more clear and secure guideline/law that ensures there are no unexpected negative consequences retrospectively due to an issue with the data privacy regulation. In response to these concerns, we would like to see a more pronounced role for data-owners in the final document. This would entail that the data-ownership remains with the organization making the data available, and that this data-provider retains more control over the circumstances under which its data can be accessible, to whom, and under what specific conditions. Another underexposed aspect is standardisation of data. Together with the DGA, an initiative to stimulate the standardisation of data in Europe, or within specific sectors in Europe, would greatly improve the efficiency and impact of data.
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