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CSC – IT CENTER FOR SCIENCE LTD.

CSC

CSC - IT Center for Science Ltd. provides digital solutions for research, scientific computing, and higher education.

Lobbying Activity

CSC urges EU to prioritize data sovereignty and infrastructure

22 Dec 2025
Topic — The European Commission is reviewing the 2030 targets for digital transformation and infrastructure.
Message — CSC calls for new targets supporting European data sovereignty and high-quality data for ethical AI. They advocate for European web infrastructure and supercomputing to reduce dependency on foreign providers.123
Why — Increased funding for data infrastructure would secure CSC's role as a leading European supercomputing operator.45
Impact — Foreign technology firms would lose market dominance as Europe builds its own competitive data ecosystems.6
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CSC urges EU to link quantum act with supercomputing

15 Dec 2025
Topic — The EU plans to accelerate quantum technology research, development, and industrial deployment.
Message — The Act should combine quantum tech with high-performance computing and AI. Policies must support hybrid computing that uses the strengths of different technologies. The EU should create shared infrastructure services for industries.123
Why — This approach leverages their existing supercomputing assets to secure future market leadership.45
Impact — Non-EU vendors may lose market share as Europe prioritizes its own supply chains.67
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Meeting with Manuel Mateo Goyet (Acting Head of Unit Communications Networks, Content and Technology)

3 Dec 2025 · Exchange of views on data centre capacity in Finland and the EU more broadly and EU initiatives in the area.

Finnish Research Center Urges Concrete Plans for EU Digital Infrastructure

12 Nov 2025
Topic — EU's long-term budget proposal for competitiveness funding including digital technologies.
Message — CSC requests concrete implementation plans for digital sovereignty, particularly regarding EuroHPC's future. They advocate for sustainable long-term funding of AI, quantum, and data ecosystems with European data ownership. They call for federated European data platforms built on existing infrastructure and a European web data infrastructure.1234
Why — This would secure continued funding for their supercomputing and data infrastructure operations.56
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Meeting with Eva Maydell (Member of the European Parliament)

4 Nov 2025 · EU Tech Agenda

Meeting with Saila Rinne (Head of Unit Communications Networks, Content and Technology)

22 Oct 2025 · AI and data management in healthcare

Meeting with Katri Kulmuni (Member of the European Parliament)

15 Oct 2025 · Ajankohtaiset EU-.asiat

Meeting with Antti Timonen (Cabinet of Executive Vice-President Henna Virkkunen), Silvia Bartolini (Cabinet of Executive Vice-President Henna Virkkunen)

15 Oct 2025 · Exchange of views on the HPC/AI Factories/Gigafactories developments

Meeting with Maria Cristina Russo (Director Research and Innovation) and

15 Oct 2025 · Exchange views on AI in science

Finnish IT Center Urges Comprehensive Digital Regulation Simplification

14 Oct 2025
Topic — EU initiative to simplify digital legislation covering data, cybersecurity, and AI rules.
Message — The organization requests careful simplification without rushing, uniform EU-wide application to prevent fragmentation, and clearer guidelines especially for SMEs on cybersecurity reporting. They emphasize building on community standards and ensuring coherence across all legislation through cross-administrative cooperation.12345
Why — This would strengthen European data platforms and reduce their dependence on non-European competitors.678
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Finnish Research Center Urges Data Infrastructure Investment for Innovation

1 Oct 2025
Topic — EU framework to strengthen Europe's innovation ecosystem and competitiveness.
Message — The organization requests prioritizing data access and infrastructure for European innovators, including a European web index and integration with EuroHPC AI resources. They emphasize building data capacities and skills for data-driven innovation.123
Why — This would make European innovators more competitive and less reliant on non-European tech giants.45
Impact — Non-European tech giants lose their monopoly control over web search and data infrastructure.6
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Meeting with Sirpa Pietikäinen (Member of the European Parliament)

24 Sept 2025 · EU Digital Policy

Response to European Research Area (ERA) Act

10 Sept 2025

CSC strongly supports the EUs goal to boost the performance of Europes research and innovation system with an ERA Act that incentivises RDI spending, better integration and coordination of national and EU-level efforts. CSC would like to stress the importance of strengthening research infrastructures and open science and research as enabling conditions for research and innovation that boost economic competitiveness and resilience. Research infrastructures, in particular digital ones, are key enablers of cutting-edge research and innovation that allow researchers and innovators to exchange data, methods, and expertise. They are also indispensable for strengthening Europes own technological capacity, European peoples skills and competencies and reducing critical dependencies. It is thus critical to ensure consolidated and sustained funding for research infrastructures both nationally and at the EU level, with the latter focusing especially on bringing European added value by developing excellent, world-class infrastructures that can encourage researcher mobility and attract and retain talent. Transnational, excellence-driven infrastructure access can support European research leadership and the fifth freedom of a single research area. In addition, the ERA Act should foster better coordination of the currently fragmented research infrastructure landscape and its stronger integration with other research policy goals and funding programmes, including Horizon Europe and the policy windows of the future Competitiveness Fund. In the era of data-intensive research, Europe must ensure data capabilities. This means reinforcing European data infrastructures but also federating data resources across different infrastructures in Europe. The ERA Act should steer infrastructures to assure excellent data management, which requires skilled people, interoperability and reuse of research data, and access to common data infrastructures, e.g. the European Open Science Cloud, in line with the European Charter for Access to Research Infrastructures. Interoperability and other FAIR data practices are core components of scientific breakthroughs and business innovation achieved by pooling resources and forming cross-border ecosystems of interconnected research infrastructures and talent, as exemplified by the EuroHPC supercomputing framework and AI Factories within the digital infrastructure domain. In addition, European ownership of research data must be ensured through data policies and governance, to boost value creation for Europe from European data. Research infrastructures have an important role in upholding and expanding open science and research the open access to publications, results, and data. Open science and research bring substantial benefits to research and society, contributing to transparency and high-quality research and innovation. Openness improves verifiability, lays ground for new insights and drives interdisciplinarity and collaboration. It increases efficiency and saves money, as sharing of data saves time. As such, it is in line with the ERAs goal to create a single, borderless market for research, innovation and technology, and goes also beyond the role of research infrastructures. The ERA Act should therefore consistently promote open science and research. Given the geopolitical context, when openness cannot be the default, the principle of as open as possible, as restricted as necessary should be applied. The legislative act must improve the framework conditions for European research by steering the policy framework to strengthen research infrastructures and open science and research practices. However, fully utilising the potential of infrastructures and open science and research requires strategic investments and upskilling across society. See the attached document for more.
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Meeting with Taru Haapaniemi (Cabinet of Commissioner Christophe Hansen)

3 Sept 2025 · The use of data and computing in the agricultural sector and the bioeconomy; emerging trends in agricultural research and innovation; agricultural bioeconomy & Bioeconomy Strategy

Finnish IT Center Urges Integrated Data Strategy for Technological Sovereignty

4 Jul 2025
Topic — This consultation explores streamlining EU data rules to improve digital data sharing and infrastructure.
Message — CSC recommends building an interoperable ecosystem that integrates supercomputing with data repositories and human skills. They call for a European open web index and harmonized regulations to reduce fragmented implementation.12
Why — This would reduce legal uncertainties and lower costs for data-based research projects.3
Impact — Non-European technology providers may face restricted access to valuable European data sets.4
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CSC Urges EU to Prioritize European-Owned Sustainable Data Centers

30 Jun 2025
Topic — The initiative aims to triple EU data processing capacity and green AI infrastructure.
Message — CSC recommends favoring European-owned operators to secure technological and data sovereignty. It suggests leveraging cooler northern climates for sustainability and expanding data center lifecycle ratings. Incentives like tax breaks should only support operators meeting strict strategic criteria.123
Why — Prioritizing northern climates and tax breaks enhances the cost-efficiency of Finnish infrastructure.45
Impact — Non-European hyperscalers would lose access to EU funding and market dominance.67
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Finnish Research Infrastructure Urges Coordinated AI-Science Ecosystem

5 Jun 2025
Topic — EU strategy for adopting AI in scientific research and creating European AI research council.
Message — CSC requests continued pooling of resources within EuroHPC for AI-enabling infrastructures including supercomputers, AI factories, and data platforms. They emphasize developing these as a mutually reinforcing ecosystem with closer synergies among EU policy initiatives and funding programs.12
Why — This would strengthen their role managing Finland's research infrastructure and computing resources.34
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Finnish IT Center Urges Coordinated EU AI Infrastructure Investment

4 Jun 2025
Topic — EU strategy to accelerate AI adoption across strategic sectors and public services.
Message — CSC calls for continued pooling of resources through EuroHPC and scaling up federated data infrastructures. They emphasize creating an interoperable ecosystem across supercomputers, data platforms, and an open web index. The organization stresses ensuring European data generates value primarily for European businesses and researchers.1234
Why — This would strengthen their role in European AI infrastructure while securing returns on existing investments.56
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Response to Quantum Strategy of the EU

3 Jun 2025

CSC commends the Commissions initiative for a comprehensive EU Quantum strategy. Quantum computing is expected to provide advances in future RDI, improving competitiveness and having a large societal and economic impact. Long-term commitment to talent development and building a sovereign ecosystem of data, high-performance computing (HPC), AI and quantum, is necessary to drive the emergence of a resilient and effective quantum computing landscape in Europe. This must also be reflected in closer synergies and coherence among relevant policy initiatives and funding programs. Technology as such doesnt create value, but the people with understanding and skills around the technology. A key challenge for advancing quantum computing in Europe is lack of expertise. The strategy must advance education of quantum computing professionals and increase general and sector-specific knowledge about quantum computing. Education and training of computing professionals must be ramped up e.g. through specialized STEM programs in universities, developing centres of excellence and networks, and continuous learning opportunities for field experts in partnership with research institutes and companies. Existing HPC, AI and quantum infrastructures must be systematically used for developing skills. In addition to boosting STEM education as such, its critical to create understanding about technology as a horizontal skillset needed in all domains. Understanding of the possibilities, risks, applications and implications of technology in different fields of research, business and governance must be increased to build a solid society-wide competence base. Expert exchanges and research visits within the EU and like-minded countries should be facilitated to create a better environment for talent development, re-skilling and RDI efforts. Building a solid competence development system also attracts talent and companies from outside EU and retains them in Europe. The accelerating convergence of different critical digital technologies underscores the need for coordinated cross-sectoral policy responses. Advances in one field, such as quantum, can rapidly influence progress in others like HPC, AI, semiconductors and connectivity and vice versa. Additionally, well-managed data and secure, sovereign and interoperable European data infrastructures are critical resources for all emerging digital technologies and for reducing strategic dependencies. An effective European quantum strategy must therefore account for these interdependencies and promote integrated approaches across relevant domains. There is also an urgent need to secure European ownership of data to ensure that value from the data is created for Europe. Ensuring that businesses, researchers, and students have access to world-leading quantum computers enabled by HPC, data and AI must be prioritized in the strategy, and coherence with parallel initiatives such as EuroHPC must be ensured. A unified approach to mitigate technological security risks and leakage is needed to ensure safe evolution of quantum technologies in Europe and globally. Adoption of quantum-safe encryption technology is crucial to protect European data. To counter quantum computers ability to crack current encryption technologies in the future, quantum-proof data encryption must be prioritized now. Adopting quantum-proof encryptions alongside conventional ones also facilitates business opportunities, establishing European actors as trusted partners. Internationally, the EU must work towards influencing global standard setting for safer data and a competitive advantage. Finally, when developing the European technology landscape, clean transition must be a priority and the EU systematically incentivize the creation of energy-efficient and cost-efficient technology solutions. The clean transition must be seen as a strength and a business opportunity for European companies, along with contributing to a more sustainable future.
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Response to European strategy on research and technology infrastructures

22 May 2025

CSC welcomes the European strategy on research and technology infrastructures, recognising its important role in providing a long-term framework for developing and coordinating these strategic capacities. Digital infrastructures are key enablers for breakthroughs in research and innovation across disciplines and sectors, providing a shared foundation for researchers and innovators to exchange data, methods, and expertise. Moreover, they are indispensable for developing and applying new technologies, building Europes own technological capacity. However, fragmentation across the infrastructure landscape limits their full potential as a unified driver for European competitiveness. The strategy must prioritise a comprehensive and interoperable infrastructure ecosystem supported by long-term investments in publicly owned world-class digital infrastructures. EuroHPC exemplifies this strategic approach through its efforts in pooling resources to develop horisontal infrastructures including high-performance computing, AI, quantum computing, data, and connectivity, and such efforts should be reinforced through the strategy. Data is the key ingredient of disruptive research and innovation. A central challenge for Europe is to fully leverage its own data assets, ensuring their ownership and security, as a key part of technological sovereignty and reducing dependencies. The strategy should scale up the efforts in federating existing data infrastructure such as the European Open Science Cloud (EOSC), the common European data spaces, the Open Web Search initiative, and the upcoming AI Factory Data Labs. This must go hand in hand with investments in computing and AI capabilities. The strategys proposed two-pillar approach that addresses research and technology infrastructures separately, risks overlooking the hybrid nature of many digital infrastructures. Infrastructures such as the EuroHPC supercomputers and the AI Factories combine elements of both, making strict categorisation challenging. These infrastructures are uniquely positioned to support the entire R&I continuum - from basic and applied research to innovation - while also serving the needs of companies, including startups and SMEs. CSC therefore advocates coordinated actions across both pillars, fostering an effective and interoperable European infrastructure ecosystem. CSC welcomes efforts to position infrastructures as drivers of talent attraction and development. Leveraging state-of-the-art research and technology infrastructures like the AI Factories can attract and retain talent and boost the continents upskilling. Additionally, these infrastructures grow talent by offering training opportunities that enhance users skills in advanced technologies and methodologies. The infrastructure strategy must support these efforts and align with the Union of Skills and other digital skills programmes. Talent development is also essential for strengthening the EUs global leadership. CSC supports promoting research and technology infrastructures as hubs for international cooperation to effectively address global challenges and develop critical technologies. The infrastructure strategy should align with the forthcoming EU international digital strategy to ensure coherence in Europes global digital engagement. One of the challenges requiring strategic European action is energy sustainability. The climate footprint of research and technology infrastructures, including data centers, is growing, driven by their massive energy demands. The strategy should promote a strong commitment to environmental sustainability and energy efficiency across the full life-cycle of research and technology infrastructuresfrom design and construction to operation and decommissioning. Encouraging the development and use of sustainability indicators can help guide progress. Operating infrastructures sustainably should be recognised as a core element of responsible research practice.
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Response to International Digital Strategy

21 May 2025

CSC welcomes the EUs objective to strengthen its global technological sovereignty, competitiveness, security and prosperity through a strategy on international digital policy. Digital technologies shape the world at an unprecedented pace, and reinforcing EU action globally enhances Europes ability to benefit from global developments in key digital areas, such as AI, high-performance and quantum computing, data management, and connectivity, while also shaping these technologies in a human-centric, responsible and sustainable direction. Given the rapid global evolution of digital technologies, research, development and innovation (RDI) must be a priority in Europes international digital strategy. Digital technologies are also becoming indispensable to scientific research and innovation, which are increasingly driven by global cooperation and competition. By leveraging RDI-focused digital cooperation with partner countries, the EU can access resources, technologies and know-how beyond its borders. This helps the Unions digital competitiveness by enhancing research and innovation, ultimately leading to better products, services and more effective responses to global challenges like diseases, global warming or loss of biodiversity. The international digital strategy must be aligned with Horizon Europe, its successor framework programme, and the Digital Europe Programme. Focusing on common European priorities and building on existing successes creates a basis for impactful and coherent international digital policy. At the same time, the strategy must steer and coordinate European RDI programmes towards growing, strategic international collaboration. In addition to leveraging Horizon and Digital Europe associations, deepening collaboration in selected fields with various countries can bring new opportunities for digital diplomacy and RDI. Data is a central factor of digital transformation. Tapping into global data flows enriches and diversifies resources available to researchers and innovators in European academia and business. Simultaneously, Europe must better utilize its own data assets, ensuring their ownership and security, as a key part of technological sovereignty and reducing dependencies. The value from data must benefit Europe, while contributing to broader global progress in research, innovation, and digital development. This requires investments in European data infrastructures, their federations and technologies such as high-performance computing, AI, quantum, and network connectivity, to process the data needed for AI models, simulations and other analyses benefiting society. Next-generation digital innovations are based on big volumes of well-managed, high-quality data, including sensitive categories like health data. Improving our own capability and ownership of such data gives muscle for international digital cooperation, too. Data and technology alone will not deliver the potential of digital transformation, but human skills, competence and knowledge are equally essential. Advancing research cooperation, knowledge exchange, and talent mobility programmes in digital technologies must be integral components of the international strategy. Leveraging and advancing state-of-the-art infrastructures like EuroHPC supercomputers and the AI Factories can attract and keep talent and boost the continents upskilling. The strategy must support these efforts with a long-term strategic view and align with the Union of Skills and other digital skills programmes. For a sustainable and human-centric digital future, the EU must seek stronger influence over global digital governance processes. Increased European engagement in multilateral fora and bilateral relations but also in more technology-specific work of standardisation bodies or international consortia, e.g. in AI, promotes European values, regulatory approaches and compatibility, and tech solutions while helping to identify operational opportunities.
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CSC Urges Public Data Infrastructure for EU Life Sciences

15 Apr 2025
Topic — The consultation seeks to develop a strategy boosting European life sciences competitiveness and prosperity.
Message — CSC recommends building shared European data infrastructures linked to supercomputers and AI factories to support research. They call for simplifying regulations and reassessing GDPR data minimisation to facilitate data-intensive innovation. Finally, they advocate for public ownership of infrastructures and sustained funding in the next budget.123
Why — Public data centers would benefit from guaranteed funding and a central role in European research.4
Impact — Privacy advocates could see protections weakened if data minimisation requirements are reassessed for AI development.5
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Meeting with Jörgen Warborn (Member of the European Parliament, Shadow rapporteur)

6 Mar 2025 · Digital infrastructure

Meeting with Andrea Wechsler (Member of the European Parliament) and Deutscher Verband der Spielwarenindustrie e.V.

12 Feb 2025 · EU Energy and industry policy

Meeting with Ann-Sofie Ronnlund (Cabinet of Commissioner Ekaterina Zaharieva)

5 Feb 2025 · Exchange of views on digital innovation and AI in science

Meeting with Hanna Anttilainen (Cabinet of Executive Vice-President Stéphane Séjourné)

5 Feb 2025 · Exchange on Artificial Intelligence (AI), data, high performance computers

Meeting with Annukka Ojala (Cabinet of Executive Vice-President Roxana Mînzatu)

5 Feb 2025 · Exchange of views of upcoming initiatives and challenges and opportunities faced by digital sector

Meeting with Antti Timonen (Cabinet of Executive Vice-President Henna Virkkunen), Silvia Bartolini (Cabinet of Executive Vice-President Henna Virkkunen)

5 Feb 2025 · Exchange views and discussion on the AI Factories/CSC-LUMI supercomputer/research policy.

Meeting with Sirpa Pietikäinen (Member of the European Parliament)

4 Feb 2025 · CSC current update

Meeting with Aura Salla (Member of the European Parliament)

15 Jan 2025 · EuroHPC, AI, Skills

Meeting with Ville Niinistö (Member of the European Parliament, Shadow rapporteur)

18 Nov 2024 · EU research policy

Meeting with Eero Heinäluoma (Member of the European Parliament)

18 Nov 2024 · EU:n TKI-asiat

Meeting with Merja Kyllönen (Member of the European Parliament)

17 Oct 2024 · Suurteholaskenta ja Lumi-ekosysteemin kehittäminen AI

Meeting with Marc Lemaitre (Director-General Research and Innovation)

26 Sept 2024 · European research & innovation landscape, including FP10 and the role and potential of digital research infrastructures, such as the LUMI supercomputer that CSC operates

Meeting with Aura Salla (Member of the European Parliament)

26 Sept 2024 · LUMI supercomputer, EuroHPC, AI Factory

Response to Interim Evaluation of Digital Europe

20 Sept 2024

CSCs position on Digital Europe Programme can be found in the attachment. Key points are briefly summarised below: DIGITAL must sharpen its strategic focus to strengthen Europe's critical digital capabilities and competencies, essential for enhancing competitiveness and prosperity. EU must recognise the urgent need for building its own competence base in all fields, for being able to develop and apply technologies, leading to the strategic capability for transforming businesses and society in a sustainable way that also helps Europe to reduce dependencies. DIGITAL must focus on leveraging investments in European High-performance computing and data infrastructures, such as the EuroHPC Joint Undertaking (EuroHPC JU) and the common European data spaces. DIGITAL must systematically aim for creating horizontal and interoperable infrastructure ecosystems, rather than targeting individual infrastructure types. Projects like Destination Earth exemplifies the convergence of high-quality, large-scale data resources and European supercomputing capacities, and must get continuous support from DIGITAL. The common European data spaces are important for unleashing the potential of data-driven research and innovation, and for retaining data ownership within Europe. Strategically selected sector-specific data spaces should be advanced in a coherent and interoperable way. CSC finds it especially important that academic research and higher education use cases are understood and enabled. An interoperable ecosystem of digital infrastructures yields societal impact only when paired with users who understand how to create value from data. Advanced digital skills is a key priority area for DIGITAL but the current actions are too numerous and fragmented. DIGITAL needs better alignment with other funding programmes focusing on digital skills, such as Horizon Europe, Erasmus+ and CEF digital. To close the digital skills gap, Europe must pool investments and agree on a coherent strategy for developing a comprehensive advanced digital skills ecosystem.' More strategic coordination between DIGITAL, Horizon Europe, and CEF Digital will create synergies, and make resources more scalable and deployable. The digital transformation requires new structures and processes, and a new collaboration culture focused on creating value from data. The interaction, synergies and differences between these funding programmes have to be clearly understood and communicated, for instance by using impactful use cases related to Artificial Intelligence. Coordination can be improved by harmonising the funding conditions in DIGITAL and Horizon Europe. DIGITALs low funding rate of 50% poses a challenge, potentially restricting the participation of the diverse set of stakeholders necessary for bridging the gap between academic research and commercial deployment of digital technologies. DIGITAL should prioritise the protection of critical technology, infrastructures, and sensitive data, while building its own digital competences to reduce dependencies. One example is to pursue the Open Web Search projects objective of creating a transparent European web index as a basis for a new Internet Search in Europe. In addition, strategic partnerships with like-minded countries, particularly in HPC, AI, and digital skills, are needed to address global challenges and foster innovation. Collaborative projects and coordinated funding with strategic partner countries should be prioritised, with more explicit recognition in DIGITAL of the benefits of international cooperation. Special attention must be paid to the climate impact, energy efficiency and cost efficiency of European infrastructure acquisitions. DIGITAL can be instrumental in encouraging digital infrastructures to make their own carbon footprint as small as possible through setting clear and impactful metrics for digital infrastructure projects in these areas.
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CSC Calls for Arctic Cables and Research-Centric Digital Infrastructure

28 Jun 2024
Topic — EU consultation on scenarios for mastering Europe's future digital network infrastructure needs.
Message — CSC wants data centers included in the digital ecosystem and Arctic submarine cables prioritized. They argue connectivity policy must align with research and innovation needs.123
Why — Improved infrastructure would enable researchers to seamlessly connect data and computing resources globally.45
Impact — Regulatory bodies seeking broader powers lose out as CSC opposes expanding telecom rules.6
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Response to GreenData4All - Revision of EU legislation on geospatial environmental data and access to environmental information

25 Mar 2024

CSC welcomes the GreenData4All initiative updating the INSPIRE Directive to improve the sharing of environmental geospatial data in support of data-driven innovation and evidence-based decision-making. Europes competitiveness and strategic autonomy in the increasingly data-intensive world depend on our ability to ensure wide availability of well-managed high-quality data and related competences in all sectors, e.g. through the Common European Data Spaces. The GreenData4All initiatives support for the Green Deal Data Space is therefore highly welcome. In order for any EU data policy to be effective, it must advance the development of data management policies and practices that are applied in a uniform manner across sectors (research, business and public) and data spaces. They must aim at making data findable, accessible, interoperable and re-usable (FAIR, www.go-fair.org/fair-principles/) and promote interoperability at all its levels: legal, organisational, semantic and technical level (European Interoperability Framework, ec.europa.eu/isa2/eif_en/). In the case of INSPIRE, it is essential to arrive at concrete solutions that promote these principles in the planned technical specifications for data and data sharing. It must be considered how all readily existing relevant data related to INSPIRE, also other than geospatial data, is made interoperable. One challenge is to make the terminology and classifications used in the INSPIREs context compatible with that of the environmental disciplines in general and with different languages, national laws and contexts. Means to improve interoperability include at least studying the field-specific vocabularies and (meta)data models used in Europe, considering the exact level of the digital object at which persistent identifiers (PIDs) are applied, and thinking whether forming data products based on different sources is possible by publishing mappings, crosswalks and workflows that refer to original sources opened with any language and schema. In the implementation, follow-up on the availability of multilingual data according to the requirements needs to be strengthened. Regarding the goal of simplifying and modernising the technical provisions for data harmonisation, attention must be paid to ensuring a reasonable transition period. Depending on how much editing the data, metadata and software require, data harmonisation can either be an easy task or very laborious. The magnitude of the changes introduced must be reflected in the length of the transition period. For the Green Deal Data Space to make a truly valuable contribution to Europes data economy, it must be made interoperable with the other sector-specific European data spaces and paired with computing and AI tools needed for combining and processing data, as well as the necessary competences and creativity for data-based value creation. Development of holistic, collaborative, and human-centric data, computing and AI ecosystems is a precondition for reaching Europes potential of a 1 trillion data economy by 2030 (European Data Market Study 2021-2023, digital-strategy.ec.europa.eu/en/library/results-new-european-data-market-study-2021-2023).
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Meeting with Marc Lemaitre (Director-General Research and Innovation)

6 Mar 2024 · Topical issues and upcoming priorities in the European research & innovation landscape, including FP10 and the role and potential of digital research

Finnish IT Center Urges GDPR Reform to Support Scientific Research

8 Feb 2024
Topic — The European Commission is reviewing the General Data Protection Regulation's application after six years.
Message — CSC requests consistent EU-wide interpretation to reduce research bureaucracy and data fragmentation. They propose clarifying pseudonymization rules and re-evaluating data minimization for data-intensive research.123
Why — This would reduce administrative burdens and costs for developing research and innovation services.45
Impact — Privacy advocates lose protections if data minimization principles are relaxed for research purposes.6
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Meeting with Sirpa Pietikäinen (Member of the European Parliament)

8 Jan 2024 · Digital twins, AI, Health Data

Response to Reporting scheme for data centres in Europe

4 Jan 2024

The ICT sectors sustainability is a crucial factor for both the EUs climate goals and the industrys own outlook which cannot neglect ambitious climate, energy and environmental targets. CSC welcomes the creation of an EU-wide data centre sustainability rating scheme and is pleased to note the comprehensive approach the draft regulation takes to the sustainability of the operational phase of a data centre. However, for the rating scheme to be truly impactful, it must address the sustainability of the whole lifecycle of a data centre from construction through the operational phase to decommissioning. A comprehensive, life-cycle based rating scheme would be a good basis for further work on reducing the climate and environmental footprint of all energy-intensive industries through EU regulations, funding programmes, KPIs and incentives. For more detailed feedback, see the attached position paper.
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Response to Evaluation of the European Union Agency for Cybersecurity (ENISA) and the European Cybersecurity Certification Framework

15 Sept 2023

CSC considers cybersecurity as one of the key issues of the digital decade and emphasises the importance of ensuring that related EU policies are comprehensive and up to date. Therefore, we welcome the evaluation of European Union Agency for Cybersecurity and EU cybersecurity certification framework and urge the Commission to perform the evaluation thoroughly, taking into account input from all relevant stakeholders. According to the Cybersecurity Act (Regulation (EU) 2019/881) ENISA shall promote cooperation, including information sharing and coordination at Union level, among Member States, Union institutions, bodies, offices and agencies, and relevant private and public stakeholders on matters related to cybersecurity. In practice, however, ENISAs outreach at national level has so far mostly been limited to public stakeholders, i.e. the national CSIRTs designated/established according to Art. 10 of the NIS2 Directive (Directive (EU) 2022/2555). Other CSIRTs have often had to rely on information exchange through commercial actors, many of which are based outside of the EU. To remedy this, ENISA should develop its cooperation with private stakeholders, in the spirit of the Cyber Solidarity Act proposal (COM(2023) 209 final) that seeks to promote further inclusion of the private sector in the efforts to strengthen cybersecurity in Europe. When it comes to the EU cybersecurity certification scheme, we welcome the work that ENISA has done so far in developing candidate certification schemes, emphasising the participation and support of the ecosystem. When developing European certification schemes, it is of utmost importance to align the schemes with the ones developed at international level (e.g. ISO/IEC 27001) in order to ensure that European companies can compete on global markets.
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Response to Interim evaluation of the European Education Area

15 Sept 2023

Considering the importance of skills and competences for Europes future as well as the increasing role that digitalisation plays in teaching and learning, the work on the European Education Area (EEA) must continue and digital aspects must remain among its key priorities. Attention must be paid e.g. to making use of remote learning and virtual mobility solutions to make learning more accessible as well as developing digital services for life-long learning. A key issue is to avoid fragmentation and ensure interoperability between the various solutions and services that are being developed. EEA must continue to address the development of learning and guidance services based on learning data analytics by providing guidelines on GDPR-compliant use of learning data and supporting the development of trustworthy AI tools for teaching and learning. Development of digital skills and competences must also remain among the priorities of EEA. These points are elaborated further in the attached position paper. Please also see CSCs earlier statements on related topics for more information: https://www.csc.fi/-/digitalisation-of-education-requires-a-strong-pedagogical-approach-csc-gave-feedback-on-the-planned-eu-recommendation-on-digital-education https://www.csc.fi/-/digital-competences-at-the-heart-of-eus-strategic-autonomy-csc-supports-the-planned-eu-recommendation-on-digital-skills https://www.csc.fi/-/more-inclusive-and-sustainable-learning-mobility-with-the-support-of-digitalisation-csc-gave-feedback-to-the-preparation-of-eu-recommendation-on-learning-mobility
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Response to Cyber Solidarity Act

10 Jul 2023

CSC considers cybersecurity as one of the key issues of the digital decade and welcomes the Commissions intention to strengthen EU action in the sector and support it with an adequate regulatory framework. A key issue to keep in mind when developing the EU cybersecurity policy is to avoid creating incoherences or overlaps when establishing new regulations and governance structures. The new Cyber Solidarity Act proposal addresses some very important questions related to e.g. pooling and sharing of data on cyber threats and incidents as well as strengthening the cooperation between public and private sector actors. However, it is questionable whether the creation of a new regulation with new governance structures and competent authorities is necessary to improve the current situation. For example, the creation of separate national Security Operations Centres (SOCs) seems superfluous as the tasks foreseen for the SOCs could be performed by the CSIRTs established by the Cybersecurity Directive. Also, the use of the term SOC for a public function may lead to confusion as this term is already well-established for private sector actors. As a positive example of relying on existing structures, we welcome the reference to EuroHPC as a partner in developing advanced artificial intelligence and data analytics technologies for the cybersecurity sector. On the other hand, a separate certification scheme for the trusted providers in the framework of the EU Cybersecurity Reserve seems unnecessary considering that existing certification schemes (e.g. ISO/IEC 27001) could be applied instead. As a general rule, any cybersecurity policy must be mindful of the fact that all actors are responsible for managing their own cybersecurity incidents. Regulation must not create situations where organisations will start relying on national or European public authorities to take care of the management of incidents on their behalf. Cooperation and information sharing can and must be strengthened but responsibility cannot be outsourced.
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CSC Urges Including Digital Policies in EU 2040 Climate Plan

20 Jun 2023
Topic — The consultation process establishes a 2040 climate target for European Union climate neutrality.
Message — CSC requests integrating digital policies into the 2040 climate plan. They propose a specific sub-target for the technology sector's environmental impact. They also advocate for shared methods to measure the digital footprint.123
Why — The organization would gain increased EU funding for its green digital research and infrastructure.45
Impact — Inefficient digital providers may lose business through new sustainability labels and purchasing comparisons.6
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Meeting with Ville Niinistö (Member of the European Parliament)

23 May 2023 · Supercomputers, ehds, euroHPC (staff level)

Response to Boosting European learning mobility for all

3 May 2023

CSC welcomes the general objectives of the upcoming Recommendation, in particular the intention to link learning mobility more to digital learning opportunities. By making more use of digital means, it is possible to make mobility more socially inclusive and environmentally friendly and thereby fulfill one of the main purposes of the Recommendation. Virtual mobility will of course not replace physical mobility altogether but it can complement it, while other digital solutions can support learning mobility in many other ways. Virtual mobility can provide opportunities for those who cannot or do not want to participate in physical mobility for some of the reasons identified in the surveys referred to in the Call for Evidence, such as lack of financial means or disability. In these cases, it is important to design the virtual mobility opportunities so that they resemble physical mobility as much as possible by e.g. providing opportunities for genuine interaction and making use of extended reality which, according to the Tech Trends 2023 identified by CSCs Dutch sister organisation SURF (surf.nl/en/tech-trends), can be applied in many promising ways in the field of education. For some learners, hybrid options combining virtual and physical mobility may be ideal solutions. A longer virtual mobility period could include a short physical mobility period which may be easier to arrange for those who feel insecure about living more permanently in another country on their own, have a family to care for etc. Virtual mobility can also be used as a way to promote physical mobility. Being able to familiarise oneself with a learning institution abroad via virtual means can lower the threshold for participating in a physical mobility period or even studying a degree or a part of a degree (micro credentials) in the same institution later on. The European University Alliances provide an excellent platform for exploring the various opportunities virtual or hybrid mobility presents as well as creating and sharing related best practices. In addition to providing opportunities for virtual mobility, digital solutions can support mobility in many other ways, such as ensuring smooth cross-border mobility of learner data, study records etc. The most urgent issue related to such solutions at the moment is fragmentation. Various solutions have been or are being developed, such as EMREX, Europass and the European eID, but interoperability between them is lacking. This must be addressed promptly to ensure coherent development of the digital support services of learning mobility. Another way for digitalisation to support mobility is to make more use of data and AI for learners to be able to find learning opportunities tailored to their specific needs. Here too, interoperability between the various existing or upcoming solutions, such as those developed in the frameworks of the European Data Space for Skills and Finlands Digivisio 2030 (digivisio2030.fi/en), is key. In addition to finding the most suitable learning opportunities, these systems could also provide suggestions related to the practicalities of mobility, such as travel and housing. Finally, CSC would like to commend the Commission on the use of the term learning mobility that emphasises the wide nature of mobility that extends beyond traditional student mobility in line with the Council Conclusions of 26 February 2021 on the European Education Area emphasising learners opportunities to pursue their studies in different stages of life. In that vein, we would like to see particular emphasis being placed on the mobility of adult learners in the future, to support continuous learning. This will be key for ensuring that Europeans have up-to-date competences and can thereby use their full potential to lead meaningful lives and contribute to innovation, growth and well-being in Europe.
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Response to Key performance indicators for the Digital Decade policy programme 2030

13 Mar 2023

CSC welcomes the draft implementing decision on the key performance indicators of the EUs 2030 digital targets. However, we continue to regret the rather sporadic and narrow nature of the targets themselves. We hope that the 2026 review of the targets, as provided for in Recital 20 of the Digital Decade policy programme, will indeed expand the targets to cover the data economy, sustainability, cybersecurity and other relevant dimensions that are missing from the current targets. Taking a more comprehensive approach is instrumental in order to go beyond the merely technological aspects. It means recognising the profound systemic change that digitalisation drives, and only this recognition enables reaping the benefits for the economy and society at large. More comprehensive target-setting will require an approach that moves away from administrative silos, similarly to how Finlands national digital compass has been prepared in good cooperation across all ministries. It is also crucial to design the KPIs so that the right issues are measured. This can be done already before the 2026 review by using the KPIs of the existing targets to widen the scope of the targets as much as possible, aiming to take into account also the societal implications. The Commission is already suggesting such widening for target 1a by adding gender convergence in the KPI, although this aspect is regrettably not featured in the target itself. In the attached position paper, we recommend similar approach for some of the other indicators. In summary we recommend the following: Target 1b: Measuring not only the number of ICT specialists as a whole but also in the sectors that are key for the development of the digital single market and data economy, e.g. data management, data analytics, AI and quantum development, cybersecurity; also, measuring digital skills in other fields than ICT, e.g. law, economics, social sciences. Target 2c: Measuring not only the number of the edge nodes but also their interoperability with the wider ecosystem of data and computing infrastructures; also, the climate-neutrality of the edge nodes mentioned in the target must be reflected in the KPI. Target 2d: Measuring the interoperability of quantum infrastructures with the rest of the ecosystem as well as the number of qubits in Europes top quantum computers. Targets 3a and 3b: Measuring the cooperation between enterprises and higher education institutions + clarifying the footnotes. Target 4a: Measuring not only the provision of digital public services but also the uptake of those services and/or the citizens ability to use them as well as interoperability between the services. Target 4b: Assessing how the mechanisms for citizen online access to health data support access for secondary use purposes. Target 4c: Assessing also the Union-wide recognition of the national eIDs.
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Meeting with Anthony Whelan (Cabinet of President Ursula von der Leyen)

25 Jan 2023 · Digitalisation, including the climate impact of digitalisation, in particular from the point of view of CSC's climate-neutral data centre in Kajaani, Finland, where LUMI is located

Meeting with Mauri Pekkarinen (Member of the European Parliament)

24 Jan 2023 · Discussion on Information Tecnhology

CSC IT Center urges risk-based approach for cybersecurity rules

23 Jan 2023
Topic — EU initiative setting cybersecurity requirements for manufacturers and vendors of digital products.
Message — The group supports security requirements based on product criticality to minimize development burdens. They recommend using international standards and audits to verify security across a product's life. They also call for coordinated laws to prevent regulatory inconsistencies.123
Why — These measures would lower compliance costs and help startups enter the market faster.45
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Response to European Interoperability Framework (EIF) evaluation and EU governments interoperability strategy

16 Jan 2023

Interoperability is a cornerstone of a well-functioning single market and European data economy. The European Interoperability Framework (EIF) plays a key role in advancing interoperability by drawing attention to all four layers of interoperability (legal, organisational, semantic, technical) and making recommendations from that starting point. CSC is pleased to note that the proposal for an Interoperable Europe Act (IEA) is based on the same approach as the EIF and intends to strengthen and further develop it. Please find attached CSCs position paper detailing our views on the Commissions proposal. In summary, we recommend: 1. The obligations created by the IEA must be proportionate to avoid causing unnecessary administrative burden, especially in sectors that already have strong structures steering interoperability 2. The mandate of the Interoperable Europe Board (IEB) must be wide enough to cover issues related to all four levels of interoperability (legal, organisational, semantic, technical) 3. Considering the width and complexity of the topic, the IEB must receive a wide array of expert input in its work. This must be reflected in the number and composition of the working groups to be established to support the work of the IEB. 4. There must be provisions that ensure that that the developers of the interoperability solutions will not have to share such information that would compromise security, e.g. the configurations of the servers or other production environments of the solutions. 5. It is important to build on existing work and fully leverage both European and national structures, as well as solutions developed by international organisations, especially in the research sector.
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Meeting with Christiane Canenbley (Cabinet of Executive Vice-President Margrethe Vestager)

30 Nov 2022 · Presentation of the company; digital policy.

Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans)

30 Nov 2022 · Sustainable data centres

CSC Urges EU to Exempt Researchers from AI Liability

28 Nov 2022
Topic — A proposal adapting civil liability rules to address damages caused by AI systems.
Message — CSC argues the EU should focus on technology-neutral regulation that targets societal impacts. They demand that rules only concern final products and services, excluding underlying research. Liability must remain solely with product developers rather than researchers sharing open-source components.123
Why — This protects research institutions from legal risks while promoting open-source data sharing.4
Impact — Parties seeking damages from foundational research errors may face restricted legal recourse.5
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Response to Enabling factors for digital education

16 Sept 2022

Digitalisation is transforming all sectors of the society, and education is no exception. It is crucial for the education sector to not only adapt to the transformation but actively shape it and make full use of the opportunities it presents. Therefore, CSC welcomes the efforts to determine a coherent approach to this phenomenon at EU level in the form of a Council Recommendation. Digitalisation of education extends far beyond technological aspects and must be addressed with a strong pedagogical approach. CSC is pleased to note that one of the aims of the Recommendation is indeed to create guidelines for digital pedagogy. The starting point of these guidelines must be learner-centricity. This entails that education systems allow for building individual learning paths and that learners receive the necessary guidance for creating their own paths, preferably supported by their personal learning data. Data can play a big part in digitalisation of education, both at the level of individual learners and that of education providers and systems. Learning data analysis allows for assessing learning results and suggesting the most suitable learning methods and paths for each learner and also improvements at institutional and/or system level. In some cases, data can also be used as an educational resource. While increased utilisation of data can bring major improvements to the functioning of education providers and systems as well as individual learning results, it is crucial to ensure that data use is controlled and ethical, paying due attention to privacy and data protection. Students must always have the right to determine how their data is used, according to the MyData principles (mydata.org). An obvious cornerstone of digital pedagogy are teachers and educators who must be able to navigate the digital world and feel comfortable with using digital solutions in teaching. Education professionals must be offered opportunities and rewarded for updating their competences in digital pedagogy in a continuous manner as a part of their professional growth. There must also be opportunities for mutual learning and sharing of best practices among teachers and education providers, both nationally and internationally. Strong digital pedagogy must be paired with the necessary technical solutions, i.e. tools, platforms and materials for digital teaching and learning as well as related user support. The solutions must be developed in good cooperation across all levels and fields of education in order to ensure their interoperability and thereby pave the way for the creation of a seamless path of digital services for lifelong learning and cross-border mobility. Due attention must be paid to the quality and availability of open educational resources. The resources must be diverse and interactive, and they must support learning of theoretical and practical skills alike. Licensing systems must be designed so that learners’ access to learning resources will not be restricted in a way that hampers lifelong learning. Other issues that must be addressed when creating digital learning opportunities include remote assessment and recognition of competences as well as remote identification of learners. These require safe, reliable and user-friendly digital solutions that are capable of preventing counterfeiting and preferably allow for cross-border use.
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Response to Improving the provision of digital skills in education and training

16 Sept 2022

What really lies at the heart of Europe’s strategic autonomy are skills and competences, in particular the ones that help us strengthen our economies and societies in the digital era. Therefore, CSC welcomes all EU policies aiming to boost the development of digital skills and competences, including the upcoming Council Recommendation. In line with the skills-related targets set in the framework of Europe’s Digital Decade, the Council recommendation on digital skills must address both basic and advanced skills. It must, however, be acknowledged that the borderline between the two is not clear-cut. What is considered advanced now, may well be considered basic in the future. For example, progamming used to be considered something quite advanced but nowadays it is taught in elementary schools in many parts of Europe. In the same vein, we must be prepared to constantly update our definition of basic skills to keep up with the evolving skills requirements of the rapidly digitalising world. One area where a certain level of skills is required of everyone is data. Education systems must be able to ensure that all Europeans have a basic understanding of how data is created, what it can be used for and what rights we have as to our own data. The more wide-spread this basic understanding becomes, the better European companies will be at seizing the opportunities of data economy. This must of course be paired with increasing numbers of specialists with advanced data skills who will be able to help the companies put their data strategies in practice. Other fields in which more specialist skills are needed include AI, quantum, High-Performance Computing and cybersecurity. Considering the rapid technological development, people must be offered continuous opportunities to update their skills and competences at all levels of education and in work life. Not all education needs to lead to a full degree but people must be able to build individual learning paths consisting of smaller modules that offer an agile response to emerging upskilling or reskilling needs. In order to create a true competence ecosystem and to anticipate the skills needs of the labour market, cooperation between the formal education system and the private sector must be deepened. Similarly, linkages between education and research must be deepened to make sure that education systems are developed based on the input and needs of the research community. In order to ensure that people are capable of continuous skills development, basic education must place particular emphasis on ‘learning-to-learn’ and other transversal skills, such as critical thinking and interaction. It must also be taken into account that digitalisation changes the skills needs in other fields than just technology. Law and business schools, social science faculties etc. must also adapt their curricula to ensure sufficient supply of legal, policy and business expertise required in the digital era. Attention must also be paid to the skills and competences of teachers and other education professionals. They must be offered opportunities and rewarded for updating their competences in teaching digital skills in a continuous manner as a part of their professional growth. There must also be opportunities for mutual learning and sharing of best practices among teachers and education providers, both nationally and internationally. In addition to the internal competence development policies described above, Europe must also boost its competence levels by attracting talent from third countries. Competence development policies must therefore be closely aligned with migration policies and migration processes made as smooth as possible by, for example, developing user-friendly digital solutions making use of automation to shorten the processing time of the applications.
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Meeting with Sirpa Pietikäinen (Member of the European Parliament)

24 Aug 2022 · Destination Earth and biodiversity twin projects by CSC

Finnish IT Center Calls for Practical EHDS Implementation Framework

27 Jul 2022
Topic — EU regulation establishing rules for sharing and using health data across borders.
Message — CSC requests emphasis on metadata interoperability, sufficient implementation time and resources, use of existing infrastructures, balanced security requirements, stronger stakeholder engagement including researchers, careful assessment of anonymisation rules, removal of automatic permit issuance, clearer publication requirements, Europe-wide consent mechanisms, and linkages with other data spaces.12345678
Why — This would allow them to leverage existing infrastructure investments and ensure workable technical requirements.910
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Meeting with Henna Virkkunen (Member of the European Parliament)

11 Jul 2022 · EU Digital Policy

Finnish IT Center Backs Swift Release of High-Value Datasets

21 Jun 2022
Topic — Defining high-value public datasets to expand Europe's data economy through open access.
Message — CSC calls for swift enforcement of high-value datasets to boost research and innovation. They emphasize data quality and suggest the proposed implementation timeline is overly ambitious. They prefer soft law to avoid establishing new regulatory barriers.123
Why — Enhanced data access would increase the efficiency of public administration and research competitiveness.45
Impact — Standardized legislative bodies lose authority as the center advocates for reduced regulation and soft law.6
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Finnish IT Center Urges Broader Data Access for Scientific Research

13 May 2022
Topic — EU proposal for harmonised rules on fair access to and use of data.
Message — The organization supports the Data Act but requests clarifications on scientific research implications and expansion of business-to-government data sharing beyond exceptional needs. They want beneficial treatment for micro and small enterprises extended to research organizations.123
Why — This would increase their access to data for research purposes and reduce costs.45
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Meeting with Miapetra Kumpula-Natri (Member of the European Parliament, Rapporteur)

12 May 2022 · Data act

Response to European chips act package – Regulation

9 May 2022

CSC recognises the vital importance of semiconductor chips for digital economy as well as the need to take action to ensure their availability in Europe. Therefore, we welcome the Commission’s proposal for a European Chips Act and, in particular, its emphasis on research and skills as these are the most crucial elements of sustainable future prosperity and technological leadership for Europe. While the emphasis on chips is welcome and appropriate, it should not draw too much attention or resources away from the development of other key technologies. Investments towards other technologies, such as High-Performance Computing, quantum, AI and data infrastructures, must remain on an adequate level despite any reallocations of HE and DEP funding. The different technologies must be developed in convergence, as an interoperable ecosystem, because digital economy is horizontal and will not function in silos. In addition, Europe must focus also on the people, skills and competences that are needed in leveraging all technologies, as well as the field-specific, end-user centric services that need to be developed as an integral part of the technologies, in order to get added value out of them. When investing in chips or any other cutting-edge technologies, it must be kept in mind that the rapid evolution of such technologies requires long-term investment plans in order to make sure that European RDI can keep up with global competition in the long run. The level of investments must also be sufficient to match the ambitions of the competitors. Finally, CSC wants to remind about the importance of a coherent European regulatory framework, that has more of an enabling than restricting impact on innovation and development of digital economy. Thus, all parallel initiatives must be reviewed, and possible legal barriers or inconsistencies systematically removed.
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Meeting with Nils Torvalds (Member of the European Parliament)

10 Feb 2022 · Digitalisation

Meeting with Mauri Pekkarinen (Member of the European Parliament)

3 Feb 2022 · Digitalization and research

Response to Policy Program - Digital Decade Compass

13 Dec 2021

Digitalisation as a systemic change, and its deep societal impact, must be taken into account in all policymaking. CSC therefore welcomes the Commission’s proposal that draws the attention of politicians, civil servants and other stakeholders to the various dimensions of digitalisation both at European and national levels. While it is important to emphasise the significance of digitalisation, this must not be discussed in a silo. The Digital Decade policy programme must be tightly connected to other relevant EU policies, such as the European Green Deal, the European Strategy for Data and the various policies related to education, research and innovation. Data as the core element of digitalisation must be recognised in this development: the societies are becoming increasingly data-intensive, and therefore we need more and more capacity, infrastructure, skills and policies to turn data into new innovation and business. Please find attached CSC’s position paper detailing our views on the Commission’s proposal. In summary, we recommend: 1. adding a new two-fold target for reducing the carbon footprint of the ICT sector: first agreeing on how to measure the footprint and then setting a target for reducing it with a view to eventually removing it altogether; 2. setting concrete targets for ensuring cross-border and cross-sectoral flow and re-use of data, e.g. by developing the common European data spaces and shared data management practices in line with the MyData principles, FAIR principles and the European Interoperability Framework; 3. extending the target regarding citizens’ access to their own electronic health records (Art. 4.1.4.b) to guarantee access to all health care professionals dealing with the individual in question as well as for secondary use, especially for research purposes, provided that appropriate methods for anonymisation/pseudonymisation are in use; 4. expanding the digital skills targets to promote horizontal and continuous opportunities to update one’s competences, improving the skills and competences of teachers as well as creation of tighter links between education, research and innovation; 5. setting a more comprehensive infrastructure target for developing an interoperable ecosystem of data management, edge computing capacities and more consolidated cloud, AI, High-Performance Computing and quantum infrastructures, allowing for data to be analysed and re-used in the most appropriate environment, taking into account the needs of different beneficiaries; 6. extending the scope and increasing the level of ambition in the target concerning Europe’s quantum capabilities; 7. setting a separate target for developing European High-Performance Computing capabilities; 8. requiring the Member States to set their own digital targets on national level taking into account their starting point in relation to the respective EU-level targets; 9. developing the Multi-Country Projects with high ambition and clear added value, seeking synergies but avoiding duplications with existing projects, e.g. fully leveraging previous work done and investments made in EOSC, GAIA-X and EuroHPC; 10. ensuring human-centricity by promoting co-design processes and digital identification solutions for cross-border use; 11. together with a wide range of stakeholders, critically evaluating the DESI index to make sure it provides relevant information in relation to the targets to be set in the Policy Programme; 12. paying attention to openness, transparency and ensuring a diverse and balanced representation of public and private interests as well as civil society and various fields of academia when organising stakeholder consultations.
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Response to European Strategy for Universities

17 Nov 2021

Higher education institutions (HEIs) must be supported in managing and providing solutions to the societal challenges related to, for example, climate and technology. Therefore, a strategy aiming at providing that kind of support at European level will be the most welcome. It is important that the strategy pays due attention to the numerous aspects of digitalisation that have a deep transformative impact on the way HEIs perform their core functions and contribute to the society. It is likely that higher education studies in the future will combine onsite and remote learning. This is a positive development as increased remote learning opportunities will improve access to higher education in a variety of fields even in more remote areas. However, particular attention must be paid to the quality and practical arrangements of remote learning. This will require developing easy-to-use digital solutions with appropriate support services for the teachers and students using them. Other aspects to be considered in the context of digitalisation of education include improving the quality and availability of open educational resources as well as solving issues related to identification of students and proctoring of exams in remote learning. It must also be kept in mind that digitalisation of education extends far beyond the technological aspects and digital education must therefore be developed with a strong pedagogical approach. Teachers need to have necessary skills and competences to be able to fully leverage the new possibilities of digitalisation, and this does not mean only digital skills as such, but also new methodologies and ways of facilitating the learning environments. Digitalisation can also contribute to the development of education and personalised learning by means of data analytics. While this can bring major improvements to the functioning of HEIs as well as individual learning results, it is crucial to ensure that data use is controlled and ethical, paying due attention to privacy and data protection. Students must always have the right to determine how their data is used, according to the MyData principles (mydata.org). When it comes to the opportunities digitalisation presents to HEIs on the research side, digital research infrastructures (RIs) play a key role. In order to provide HEIs with the best possible research conditions, it is important to work towards a cross-border ecosystem of state-of-the-art RIs where High-Performance Computing, Quantum, Cloud, AI and data repositories all play a role. A European strategy for universities can give a major boost to the cooperation and trust that the development of such a collaborative ecosystem requires. In order for the RI ecosystem to function properly, it must be fueled by abundant supply of high-quality research data. The European strategy for universities must promote the recognition of data management, based on the FAIR principles and the European Interoperability Framework, as an integral part of the research process. Efforts must also be made to ensure that publicly funded research data is always available free of charge, even if it relates to an article published behind the paywall of a scientific publication. The EU must develop ways to increase sustainable open access to research publications. If provided with access to high-quality RIs and datasets, European HEIs are better equipped to perform research that contributes to responding to grand societal challenges, such as climate change and global pandemics. Another way for HEIs to contribute to the society is by educating specialists to work on similar topics outside the academia. The European strategy for universities can enhance both of these contributions by promoting deeper links between education, research and innovation, e.g. in the form of increased partnerships with the private sector. The strategy should also discuss ways to secure sustainable funding for the higher education sector.
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Meeting with Jean-Eric Paquet (Director-General Research and Innovation)

7 Oct 2021 · Research infrastructures, research data

Response to European Digital Identity (EUid)

31 Aug 2021

CSC supports the idea of creating a European Digital Identity as this would greatly facilitate cross-border access to services as well as cross-border mobility, including in the key fields of education and research. Considering the international nature of these fields in particular, it would be useful to explicitly mention in the regulation that Member States are not limited to issuing digital identities only to their citizens or residents physically present on their soil. If deemed appropriate, digital identities should be available also to individuals residing elsewhere but studying, doing research or otherwise operating remotely in the Member State in question. In CSC’s view, the idea of moving from rigid digital identities towards provision of specific attributes related to those identities is functional and responds best to what is expected of electronic identity solutions nowadays. This approach is particularly welcome as it allows for targeted sharing of identity data depending on what attributes are required for each transaction. The users' freedom to choose what data to share with whom increases their control over their own identity data in line with the MyData and Data Sovereignty principles. At the same time, users will have greater responsibility of their own data and must be supported in making informed decisions about sharing their data. The new European Digital Identity framework implies significant legislative and technical changes at Member State level, especially due to the ambitious requirement for the new Digital Identity Wallets to meet the requirements of assurance level “high” which may prove particularly challenging for the mobile applications. Such changes will require appropriate change leadership and resourcing as well as time. This must be taken into account when setting the objectives and deadlines for the implementation of the new framework. CSC is pleased to note that the proposal pays due attention to consistency with other Union policies, especially the General Data Protection Regulation. However, certain aspects of the interplay of the EUid Regulation with the GDPR require clarification, in particular the question of who is the data controller of the attributes in the users’ wallets. If the data controller is the organisation that manages the authentic source and has written the attribute to the wallet, a number of questions arise on, for instance, the legal grounds (GDPR Article 6) of release of the attribute, ensuring minimal disclosure (GDPR Article 5.1.(c)) and the possible liability of the data controller for misconduct (e.g. poor information security practices) of the relying service. In addition to being consistent with other Union policies, the new legislative framework must take into account existing solutions in its own field, including the ones developed in the private sector. In general, further cooperation between the public and the private sector must be promoted and innovation in both sectors encouraged. It is also important to ensure interoperability both between the solutions developed by different Member States and between the public and the private sector. Interoperability is a key prerequisite in developing well-functioning and user-centric Pan-European digital frameworks. The proposal pays due attention to ensuring interoperability but leaves the details for Member States to agree in the form of a Toolbox defining the technical architecture, standards and guidelines of the framework. The Toolbox will be crucial for ensuring uniform implementation across the Union and must therefore be prepared carefully. Preparation must include all relevant stakeholders and be allowed sufficient time, most likely requiring a revision of the timeline foreseen in the Toolbox Recommendation. The results of the Toolbox work must be also evaluated when reviewing the Regulation (Art. 49) and, if need be, included in the revised Regulation to make them legally binding.
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Response to Policy Program - Digital Decade Compass

12 Jul 2021

As the Digital Decade process is moving to its next stages, CSC wants to reiterate the importance of the green and human-centric approach that is quite prominent in the roadmap for the Digital Compass communication published in February. It is essential not to lose sight of these underlying principles that stem directly from the Commission’s most fundamental political and strategic priorities, outlined in the Green Deal and plans for making Europe fit for the digital age. Furthermore, the digital and green transition must interplay as a twin challenge and opportunity in the proposed targets and tools. Please find attached CSC’s position paper on how to keep the Digital Decade green and human-centric. In summary, we recommend: 1. Setting a climate-neutrality target for all digital infrastructures with vast energy consumption; 2. Drawing up a Green ICT Strategy for the EU, inspired by Finland’s recently published climate and environment strategy for the ICT sector; 3. Enhancing the end-user’s role in the design of digital services through co-design and engagement of broad range of user communities; 4. Setting an interoperability target and linking the Digital Compass policies more closely with the EU’s data policies; 5. Developing the infrastructure targets so that they support interoperable ecosystems of different types of infrastructures as well as technological leadership in emerging technologies; 6. Applying shared ownership and inclusive consortium arrangements when designing the Multi-Country Projects for developing Europe’s digital capacities in critical areas; 7. Paying attention to openness, transparency and ensuring a diverse and balanced representation of public and private interests as well as civil society and various fields of academia when inviting members to the stakeholder forum and/or expert group to be established to support the implementation of the Digital Compass policies; 8. Consulting stakeholders not only on the implementation but also the design of the Digital Compass policies, and taking the necessary communication efforts to that effect.
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Finnish research center urges flexible AI Act to avoid stifling innovation

9 Jul 2021
Topic — EU regulation establishing harmonised rules for artificial intelligence systems and fundamental rights.
Message — The organization requests generic AI definitions that regulate purposes rather than technologies, and clearer requirements for high-risk systems. They argue technology-specific definitions quickly become outdated and create loopholes, while vague terms like 'psychological harm' allow arbitrary interpretation.123
Why — This would allow their research activities to continue without barriers from outdated definitions.4
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Response to Pact for Research and Innovation in Europe

12 May 2021

CSC welcomes the idea of assembling the key values and principles of the European Research Area (ERA) in a single legal act and agrees that a Council Recommendation is the appropriate instrument for this purpose. The resulting ‘Pact for Research and Innovation’ will give a further boost to ERA and help it leverage the potential of European R&I in enabling Europe’s green and digital transition. One of the aims of the Pact must be to develop collaborative, federated and interoperable research ecosystems that allow for sharing research infrastructures, data, tools, methods, skills and competences across borders and sectors. This requires efforts to strengthen collaboration and trust between Member States, institutions and research communities, as well as sustainable investments in European state-of-the-art research infrastructures that enable convergent use of data, computing and AI capacities. Such infrastructures must be cost-efficient and environmentally sustainable, building on top of existing infrastructures and leveraging work already done within the framework of European RIs and e-Infrastructures. When considering the environmental sustainability of the digital infrastructures for research, their dual role in impacting the green transition must be acknowledged: on one hand, they are instrumental for conducting research that helps to fight climate change and protect the environment; on the other hand, their own power consumption and the resulting emissions are often very high. The Pact must look for ways to increase the positive impact and reduce the negative one. CSC is pleased to note that openness, excellence and mobility of researchers are explicitly mentioned in the roadmap as key values and principles that the Pact aims to reaffirm. When it comes to openness, the interpretation must be as broad as possible and cover all aspects of open science and research. Multi-disciplinarity must be cherished and supported in every way. Open access to not only research data, but also tools and methods, must be ensured. Data management must be recognised as an integral part of the research process and developed based on the FAIR principles and the European Interoperability Framework. Publicly funded research data must always be available free of charge, even if it relates to an article published behind the paywall of a scientific publication. The EU must develop ways to increase sustainable open access to research publications. Excellence must be supported by securing a sufficient level of investments for R&I in Europe as well as by promoting global academic cooperation based on reciprocity and jointly agreed global standards and practices for e.g. data management. Mobility of researchers must extend to the whole world in order to promote maximal knowledge circulation and diversity in academia. Diversity must be recognised as an important success factor, and it must be interpreted broadly to include not only gender equality but improved inclusion of all under-represented groups in order to ensure diversity of thought and, as a result, diversity of research fields, topics and approaches. Finally, as higher education and research go hand in hand, CSC would like to see more connections between the European Research Area and the European Education Area. We believe, that aiming for more synergies between these areas, more excellence and impact can be created.
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Response to Digital Services Act: deepening the Internal Market and clarifying responsibilities for digital services

30 Mar 2021

CSC recognises the need to update the regulation of the digital services market in order to adapt it to the evolving operating environment and to make the market safer and fairer for consumers as well as service providers of different types and sizes. The Commission’s proposal for a Digital Services Act contributes to this endeavour and is therefore highly appreciated. CSC is particularly pleased to note that the proposal acknowledges the need to evaluate the systemic risks related to very large online platforms and intends to facilitate academic research on this topic by giving vetted researchers access to the data that is needed for performing such evaluation. CSC also warmly supports the proposal’s user-centric approach aiming at providing citizens and business users with more choice as well as more transparency when it comes to advertising, content moderation decisions etc. The aim should be to create an interoperable service ecosystem where the users can freely compare, choose and change service providers according to their needs. The proposal concerns intermediary services which are divided into different categories in two ways: mere conduit / caching / hosting; and all services / hosting services / online platforms / very large online platforms. In some cases, it may be difficult for service providers to identify which categories they belong to, if any. Therefore, particular attention must be paid to communicating clearly the scope of the regulation to the parties concerned, perhaps by offering further examples of services belonging to each category or making advisory services to this effect available for service providers. As the enforcement of the regulation will be largely a responsibility of the Member States, it is important to ensure a shared understanding of the way in which to put the enforcement measures into practice. The new European Board for Digital Services can play a major part in ensuring uniform enforcement and must therefore be equipped with adequate powers and resources. Only by guaranteeing harmonised enforcement across the Union will it be possible to reap the full benefits of the new regulation.
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Response to Revision of the NIS Directive

17 Mar 2021

CSC welcomes the Commission’s proposal and especially its ambition to further harmonise the level of cybersecurity across the EU by expanding the scope of the Directive, spelling out many of its requirements in more detail and equipping the Member States with more stringent supervision and enforcement powers. Cybersecurity is a field where clear and robust common rules are needed, and the Commission’s proposal is clearly a step in the right direction in this respect. CSC also appreciates the more strategic and forward-looking approach where more focus is put on policy-level cooperation among the Member States as well as measures concerning cyber threats, risks and vulnerabilities rather than just incidents. The new peer review system (Art. 16) must be used effectively to promote policy-level cooperation among the Member States as well as more harmonised implementation of the Directive across the Union. Harmonisation, along with more proactive security measures, will also be supported by the use of cybersecurity certification schemes as suggested in Art. 21 of the Commission’s proposal. In this context, it would be most efficient to endorse well-known international security certifications, such as ISO 27001. In the context of cybersecurity regulation, any underlying political considerations, such as those related to Europe’s digital sovereignty, must be made as transparent and explicit as possible. Their potential impact on cost and access to state-of-the-art technologies must also be acknowledged and assessed, in order to reach the best possible added value for Europe. In general, improving Europe’s digital resilience and sovereignty is a good objective that must be supported with broad-scale measures to develop European technological competences and skills. At the same time, excellence, cost-efficiency and environmental sustainability must remain the main criteria for developing the digital infrastructures in Europe. Cybersecurity issues cannot be solved and managed by government actions and government agencies alone. CSIRTs (Computer Security Incident Response Team) and ISACs (Information Sharing and Analysis Center) have vital and well-established roles in incident mitigation and prevention. It is very important to ensure an early flow of trusted information on vulnerabilities and incidents between governmental CSIRTs as well as CSIRTs and ISACs in the private sector and in the NRENs (National Research and Education Networks) and research infrastructures. Existing mechanisms for trust, such as the Trusted Introducer Protocol and SIM3 or Sirtfi certification, should enable access to some early information on vulnerabilities and incidents. Considering the vital importance of timely and efficient information flows, CSC is pleased with the proposal's emphasis on increasing cooperation and information sharing among the authorities and service providers covered by the Directive, especially the obligation for the Member States to facilitate information sharing among essential and important entities (Art. 26). When identifying the parties and channels of information sharing, all existing networks, such as those between the private-sector CSIRTs and ISACs described above, must be fully leveraged. The aim must be to allow for as much information sharing as possible without compromising on confidentiality. CSC is also happy to see that the national cybersecurity strategies are to include a policy on supporting academic and research institutions to develop cybersecurity tools and secure network infrastructure (Art. 5.2.f). These policies must also fully leverage existing structures and prior self-regulation efforts, e.g. in the framework of the emerging European data infrastructure landscape and ecosystems, including European Open Science Cloud, GAIA-X, EuroHPC and European research and education networks.
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Response to Europe’s digital decade: 2030 digital targets

9 Mar 2021

CSC welcomes the plan to formulate a new vision for Europe’s digital transformation and especially the human-centric approach. This requires developing user-centric digital services by e.g. ensuring people’s control over their personal data, and improving interoperability between digital services to improve consumer experience. Data is in the core of digitalisation and must therefore be recognised as a key element in all areas. Thus, it is crucial to adhere to MyData principles*, FAIR principles* and the European Interoperability Framework*. CSC appreciates the intention to ensure synergies between the digital and green transitions. The pioneering work done in Finland to create a climate and environment strategy for the ICT sector* provides useful input to the European vision. When considering the environmental impact of the ICT sector, it is important to keep in mind its dual nature: 1. the sector causes GHG emissions (carbon footprint); 2. it creates solutions for reducing emissions in other sectors (carbon handprint). Another key starting point for the new vision is coherence of EU’s digital goals. This requires making sure concrete targets and actions to implement the vision never lose sight of the underlying principles, such as the human-centricity and environmental sustainability. Europe’s digital sovereignty must be strengthened in line with the principles of global cooperation and open science that European RDI needs to thrive. At the level of capacity building, coherence requires creating synergetic, interoperable and federated data ecosystems by developing high-performance computing, data management, AI and connectivity networks in convergence. Data flow across sectors and borders must be ensured as well as use of sensitive data for R&I purposes, taking inspiration from the work done in Finland on use of health data in ways that respect people’s right to privacy*. The vision for Europe’s digital transformation must be paired with concrete targets and actions, and it must be built on existing digital infrastructures. CSC agrees with the four dimensions that the Commission has identified, but would like to see digitalisation of education considered as part of the dimension of digital government and the Digital Education Action Plan* included among the previous strategies informing the vision. All actions must be determined based on a thorough analysis of Europe’s strengths, and continuously adapted to possible changes in the operating environment. Action is required in three areas: regulation, investments and skills development. Regulation must guarantee peoples´ rights online and support a well-functioning digital single market. Legislative barriers must be removed to ensure innovation and growth. Soft-law type of instruments and community-driven bottom-up approaches must be adopted wherever possible. Sustainable funding for digital infrastructures must be ensured, to meet the growing capacity needs for data processing. CSC warmly welcomes the intention to create Multi Country Projects, which would pool not only funding, but also human resources, and help develop and scale up innovative technologies. In particular, investment must be channeled towards supporting practical applications and commercialisation of innovations as this continues to be the weak link in European innovation processes. Efforts are needed both to provide all Europeans with basic skills and competences to operate in the increasingly digitalised world and to train a wide range of specialised professionals for the needs of the digital economy. Particular attention must be paid to transversal skills and life-long learning as both specialised professionals and ordinary citizens need to be able to continuously update their skills and competences in the rapidly evolving digital world. * links in attachment
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Finnish IT Center Urges Federated Approach to EU Health Data Space

3 Feb 2021
Topic — EU regulation establishing a European Health Data Space for cross-border health data exchange and research.
Message — The organization requests that health data remain in original locations using federated infrastructure, ensure interoperability with other data spaces, and leverage existing initiatives like 1+ Million Genomes. They emphasize data must stay within the European Economic Area.1234
Why — This would allow them to utilize existing high-performance computing investments and maintain their role as infrastructure operator.56
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Meeting with Roberto Viola (Director-General Communications Networks, Content and Technology)

18 Jan 2021 · LUMI Supercomputer state of play - video meeting

Response to Achieving the European Education Area

25 Aug 2020

CSC supports the Commission’s ambition to create a European Education Area (EEA) by 2025 with a horizontal approach, taking into account EEA’s contribution to Europe’s socially and environmentally sustainable growth as well as recovery from the COVID-19 pandemic and future resilience. CSC is particularly pleased to note that EEA will continue to emphasise the importance of lifelong learning as the ongoing rapid technological and societal transformations increase the need for continuous competence development in a way that presents a major challenge to the European education and training systems. EEA must be firmly linked to EU’s digital policies in order to ensure, on the one hand, that Europeans have the necessary skills and competences for the increasingly digitalised world. On the other hand, education and training systems must be empowered to fully exploit the opportunities of digitalisation. These opportunities can range from various tools, platforms and materials for digital teaching and learning to the creation of digital services for lifelong learning and international mobility or systematic data-based quality assessment of education and training providers. COVID-19 pandemic has forced education and training systems to digitalise themselves very quickly. It is of utmost importance that the lessons learned from this development are analysed and best practices shared. Some tentative conclusions can be drawn from CSC’s preliminary analysis of the impact of the pandemic on the Finnish higher education institutions. The necessary service infrastructure in terms of network and applications for remote learning was scaled successfully but what is clearly needed in the future is stronger interoperability and collaboration between organisations, shared assessment practices and free flow of information and data. Considering that future learning and teaching will most likely combine onsite and distance learning, efforts must be made to make sure that learning remains accessible for all and that adequate support services are available for learners and teachers using digital solutions. It must be kept in mind that digitalisation of education is a multidimensional phenomenon that extends far beyond the technological aspects. Digital education must therefore be developed with a strong pedagogical approach and according to the same principles and objectives as education in general. This entails paying due attention to questions related to equity, privacy and data protection. For example, learners need to have an opportunity to determine how their data is used, according to the MyData principles (mydata.org). Open educational resources play a key role in ensuring that inclusive education and training can be provided for all learners. The quality and availability of educational resources must therefore be improved at a large scale. While there have been successful implementations by frontrunners, there is a need for a modern platform for sharing and utilising materials effectively and ways to encourage both teachers and institutions to share their work. Another issue to be considered is assessment and recognition of competence; both prior learning as well as what is learned during training. Reliable and legally sound methods of identification of learners and remote proctoring of exams need further development. At the same time, there is a need to develop ways to validly assess competence remotely. Exams may be the norm but they do not cover all areas of competence. Because of the vast potential that digital solutions can offer to education, EEA and Digital Education Action Plan need to be developed in close convergence. In addition, it is important to create tighter linkages between research and education, which will strengthen the competence base and resilience by putting focus on the competence development of future researchers. This requires closer links between related European bodies and policies (EHEA, ERA, EEA).
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Response to Implementing act on a list of High-Value Datasets

24 Aug 2020

Developing data economy boosts innovation that is crucial for Europe's future competitiveness and wellbeing. In order to support this development, Europe must make efforts to improve both the quality and quantity of freely available data. The Open Data Directive and the upcoming implementing act on high-value datasets (HVD’s) are important building blocks of the European data economy and must therefore be swiftly implemented and enforced. CSC supports the selection of high-value datasets based on their high social, economic and environmental potential and acknowledges the contribution of such datasets to the creation of the common European data spaces foreseen in the European Strategy for Data (COM/2020/66 final). Making high-quality public datasets freely available will have a number of positive consequences. First, it will encourage other actors to also improve the quality, accessibility, availability and re-usability of their data. Second, it will result in wider re-use of public sector data which will in turn increase the efficiency of public administration. While deeming the quality of the high-value datasets highly important, CSC understands the need to balance the technical requirements of the datasets with the implementation capacity of the data holders. CSC also agrees with the definition that ‘data excluded or restricted from access by virtue of national law or Union law will not be taken into account for the list of high-value datasets’ as this will make it easier for the Member States to enforce the initiative. In CSC’s view, it is particularly useful to have the high-value datasets bundled with geospatial data and to enable additional bundling with sensor and mobility data. The expected wide availability of climate-related datasets is also highly important as it supports the digital innovations, research and coordinated policy-making needed for tackling the climate crisis. Having the UN 2030 sustainability goals widely accepted, better availability of company data will improve market transparency and thus assist in building a more transparent society allowing civic oversight and to fight against fraud and abuse. In order to create a flourishing data economy, the EU must put more focus on supporting the usage of data by startups and SMEs, aiming for free flow and high level of re-use of data between sectors, leading to new innovations and solutions, ultimately boosting European competitiveness. Thus, all barriers for data movement and re-use between different sectors must be removed. Data is cross-sectoral and horizontal in nature, thus it requires a comprehensive, holistic approach. Thus, all parallel regulations and initiatives concerning data must be reviewed and made coherent at European level. Europe must systematically avoid building new barriers for data movement, and the need for new regulation must be critically assessed. Instead, soft law and common practices approaches must be developed, and active attempts to reduce and harmonise legislation must be made across the Member States.
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Response to Communication on the future of research and innovation and the European Research Area

30 Jul 2020

CSC agrees with the need to revitalise ERA in order to leverage the potential of European R&I in enabling the ecological and digital transitions that Europe is facing. From CSC’s point of view the main building blocks of a successful ERA are sufficient and strategically directed research funding, state-of-the-art research infrastructures, availability and quality of research data as well as policies that promote competence development, diversity and mobility of researchers. It is of utmost importance to ensure sufficient funding levels for R&I activities in the upcoming multiannual financial framework and to focus on excellence as the main criterion when allocating funds. Sufficient part of the funding must be directed towards new research infrastructures while making sure that the existing ones are leveraged to their full capacity. Different types of infrastructures must be developed in coherence. For example, the interactivity of computing and data infrastructures must be ensured and the linkage between EuroHPC and EOSC strengthened. As research becomes increasingly data-intensive, it is crucial to ensure the sustainability of the underlying infrastructures that enable multi-disciplinary research, to tackle grand challenges. In addition to building data infrastructures, attention must be paid to developing data management practices that ensure the availability and quality of research data. Data management must be recognised as an integral part of the research process and developed based on the principles of open scholarship (see https://www.knowledge-exchange.info/projects/project/open-scholarship) as well as a comprehensive interoperability framework, where different levels of interoperability are developed in coherence. The European Interoperability Framework (https://ec.europa.eu/isa2/sites/isa/files/eif_brochure_final.pdf), developed by the European Commission, should serve as an inspiration and guideline. Considering that ERA is expected to emphasise health research in the aftermath of the COVID-19 crisis, due attention must be paid to the need for cross-border exchange of health data and its secondary use for research purposes. In order to ensure high-quality research, attention must be paid to competence development of researchers. This requires closer links between education and research and the related European bodies and policies (EHEA, ERA, EEA). Gender imbalances and other inequalities in academia must be addressed in order to ensure the diversity of research topics and approaches. Mobility of researchers must remain a priority as it can contribute to not only diversity but also competence development as it promotes circulation of knowledge, including on research infrastructures and data management practices.
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Response to Legislative framework for the governance of common European data spaces

21 Jul 2020

CSC supports the idea of a horizontal governance model for the common European data spaces, based on a comprehensive interoperability framework, where different levels of interoperability are developed in coherence. The European Interoperability Framework, developed by the European Commission, serves as a good basis. Legal interoperability: In development of data infrastructures, hard law options are to be considered only as a last resort. Europe must systematically avoid building new barriers for data movement, and the need for new regulation must be critically assessed. Instead, soft law and common practices approaches must be developed, and active attempts to reduce and harmonise legislation must be made across the Member States. It is of utmost importance to evaluate existing regulation carefully. For example, the scope of the text and data mining (TDM) exception of the DSM directive on copyright must be widened also to cover commercial use. Organisational interoperability: It is crucial to agree on common policies and practices at Member State and institutional levels. Solutions must be developed in collaboration with all stakeholders. The data spaces should be built on top of the existing infrastructures, initiatives and policies, such as European Open Science Cloud. The idea of federated data infrastructures is functional for Europe: connecting existing infrastructures and making them interoperable, while also making efforts to identify and fill the gaps they may have. Semantic interoperability: Data must be made understandable for the end-user regardless of where it is re-used. Existing semantic tools such as vocabularies, ontologies and enterprise architecture models must be leveraged. In developing tools and policies for interoperability, it is important to take into account the global aspect, ensuring that all policies comply with global standards and practices. For example, the tools developed for data management in the global Research Data Alliance (www.rd-alliance.org) must be systematically integrated into developing data infrastructures wherever possible. Technical interoperability: Making the infrastructures compatible is an elementary building block for sustainable data flows, exchange and re-use between different IT systems and software applications. This must be systematically promoted in parallel and consistently with all other layers of interoperability. Joint services and easily accessible and usable tools and support to end-users are essential as well as the processes for authentication and authorization of usage. Technological solutions and planning must be based on end-users’ perspective, e.g. by using co-design model in service development. Sustainable business models, as explored e.g. in the attached OECD report, are critical to ensure the availability of publicly funded data. European data spaces must be seen as a joint, strategic European investment by all member states, to strengthen European competence and capacity. The baseline for a business model for European data spaces must be, that publicly funded data must in no circumstances become something that is put behind a paywall. Thus, the role and the business model of novel data intermediaries mentioned in the roadmap must strictly comply with the principle of making all publicly funded data (including research data) as well as the associated services, such as search and programmatic access, available for everyone free of charge. Furthermore, the overall necessity and added value of the data intermediaries must be clarified and evaluated before introducing such a new structure into the data landscape. Finally, in order to ensure quality of data, attention must be paid to validation of data and openness of methods, as well as data management practices. Skills in data processing and management need to be systematically developed on all educational levels, across all fields in education and research, including pedagogical education.
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Response to Digital Education Action Plan

14 Jul 2020

Digitalisation of education is a multidimensional phenomenon that extends far beyond the technological aspects. It enables completely new ways and methods of teaching and learning and must therefore be accompanied with a strong pedagogical approach. This requires ensuring that all teaching professionals have the resources, competence and confidence to rethink learning, teaching, assessment and related use of technology and digital solutions. Digital education and learning must be developed according to the same principles and objectives as education and learning in general. For example, core values, such as equal access to education, must be upheld. This requires a solid legal framework as well as adequate support services, both online and offline, for learners using digital solutions. Actions must be taken to ensure learners’ well-being (social services, social activities, spotting/reducing drop-outs) when digitalising education. Young learners are used to interacting digitally from the social aspect, and currently there is a gap between what learning solutions, teaching methods and campus-based services offer. Digitalisation of education creates challenges related to infrastructure, competences, data protection, equity, digital pedagogy etc. Any such challenges must be addressed but they cannot be allowed to jeopardise the larger goal of creating better services through digitalisation. The challenges are similar at all levels of education and should therefore be met with solutions developed in good cooperation across the levels of education. Such cooperation must be encouraged as it also supports life-long learning by, for example, facilitating the creation of interoperable platforms, tools and databases. Further positive impact can be reached by extending cooperation and interoperability to other related fields, such as employment services. The “new normal” in the field of education will most likely combine online and offline teaching and learning which requires developing robust and trustworthy digital and remote solutions. Open educational resources play a key role in this process and must therefore be developed further in terms of both availability and quality. Along with developing methods of teaching and assessment, another issue to be considered in this context is online assessment and recognition of prior learning as well as the related questions concerning identification of the learner, proctoring etc. Creating a safe, reliable and user-friendly identification solution would be beneficial for not only remote learning but also international mobility. Digital solutions are needed for the whole chain from recognising competence gaps and identifying learning opportunities to transferring credits etc. Such solutions require effective data flows and interoperable machine-readable data, which illustrates the need to place questions related to data at the core of the updated Digital Education Action Plan. Digital solutions are needed to achieve the objectives of the European Education Area, such as increased international mobility and cooperation of teachers and learners as well as improved recognition and validation of competences. Therefore, the updated Digital Education Action Plan must be robust and its strategic significance duly recognised.
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Response to Strategy for smart sector integration

14 May 2020

CSC - IT Center for Science Ltd. sees smart energy sector integration as an important means in pursuing the objectives of the Green Deal. Decarbonising sectors such as heating, transport and industry requires more efficient and cleaner ways to produce energy, and innovations that reduce the amount of energy needed. In addition, due to the growing amount of intermittent renewable energy, the energy systems need more flexibility and stability through energy storage and conversion between the different energy sectors. The key in achieving better integration in energy sector is technological advancement and new innovations. There is a huge potential in solving technological challenges such as power-to-X, hydrogen and processes of energy-intensive industry. In addition, there is demand for services that increase energy efficiency by optimising the energy usage. Solving the challenges related to the energy sector require top level research and innovation activities. The Commission needs to ensure that the proposed funding for Horizon Europe and Digital Europe Programme is not cut in the negotiations for the next multiannual financial framework. Sufficient funding for RDI activities, as well as good digital and research infrastructures are necessary for developing new, climate friendly technology. Even though digitalisation and ICT sector are primarily an answer to the climate problem, they use a lot of energy. The ICT sector is currently using 5-9 % of the world's electricity and the share is expected to grow to 21 % by 2030. A substantial part of the current and future consumption comes from the data centers. Therefore it is clear that actions are needed in order to decrease data centers' environmental footprint. The environmental aspects of running data centers should be taken into account to a greater extent, especially with publicly funded data centers. Data centers should be built in locations where there is a possibility to use renewable energy and free cooling or utilise the waste heat. Reusing the waste heat generated by a data center for example in a district heating network is a great example of smart sector integration. There is a lot of potential in using the waste heat of data centers in heating, as it solves two problems; the environmental footprint of the data centers reduces, and emissions of carbon intensive heating sector reduce. There are already examples of how to implement such solutions; a case for benchmarking is CSC's data center in Kajaani, which will host a EuroHPC pre-exascale supercomputer LUMI from the beginning of the next year. The waste heat generated by the center will heat up 5000 homes in the area. In addition to the utilisation of the waste heat, the circular economy thinking needs to be incorporated in the data center business extensively. It means for example exploring the possibilities to build centers on existing infrastructures and taking care of the life-cycle of the materials that are used. The EU should support environmental friendliness of data centers by placing entirely or partly EU-funded energy-intensive operations such as high-performance computing and data management in data centers that have the smallest environmental footprint. Due to the modern high-speed data connections, operations can be located even in otherwise peripheral areas. The current EU green public procurement criteria for data centers, server rooms and cloud services should be promoted and private actors should be encouraged to take the environmental aspects into account more comprehensively. The main barrier for utilising the waste heat of data centers is that it is not always economically sensible. The best tool to overcome that problem is different incentives: energy taxation, emissions trading system and funding for technological solutions that help to make the data centers more environmentally friendly (for example heat pumps, which are needed when feeding the waste heat into the district heating network).
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Meeting with Roberto Viola (Director-General Communications Networks, Content and Technology)

31 Jan 2020 · EuroHPC, DEP