CSC - IT Center for Science Ltd.
CSC
CSC - IT Center for Science Ltd.
ID: 360344017227-92
Lobbying Activity
Meeting with Christiane Kirketerp De Viron (Cabinet of Commissioner Carlos Moedas)
8 Jan 2019 · Open Science Cloud and HPC
Meeting with Manuel Mateo Goyet (Cabinet of Commissioner Mariya Gabriel)
8 Jan 2019 · High Performance Computing
Meeting with Maximilian Strotmann (Cabinet of Vice-President Andrus Ansip)
8 Jan 2019 · High-Performance Computing and research
Response to Multiannual Financial Framework: Digital Europe programme
8 Aug 2018
As a general remark, CSC finds the aim and ambition of the Digital Europe programme very relevant, and we recognize the need to increase and maximise the benefits of the digital transformation for all European citizens, public administrations and businesses.
However, the process of developing the Digital Europe Programme (DEP) has not been transparent or including enough. No public consultation was done for the programme as a whole, only for separate parts, with no indication of how these parts would be put together as a full programme. The negative opinion on the first impact assessment from the regulatory scrutiny board indicates that this programme was set up in a hurry. Even the opinion on the second impact assessment has serious reservations, questioning for instance the commitment of member states and the role of DEP related to research. The key objective, which should form the ground for all the other objectives, is to build trust and collaboration between the different stakeholders, to make efficient use of relevant existing work and to aim for interoperability and synergies, avoiding a siloed approach.
The description of the coordination between DEP and Horizon Europe, especially in the HPC area should be developed further. The difference between programmes is clearly described, but the potential synergies are rather vague. It is still not very clear how the interoperability issue is handled, and there is no mentioning of interoperability of the infrastructures in the different sectors (public-industry-research). Interoperability of data across all the infrastructures is a key factor for enabling innovation and should be highlighted more. The mentioning of alignment with European Interoperability Framework (EIF) is very good but the importance of all the aspects of interoperability should be elaborated (not only technical but also semantic, legal, organizational etc), and should be widened to apply to all European data infrastructures. Existing initiatives such as the DSM and the Data Economy must be taken into account to ensure there are no incoherencies - especially as data is a key element in digitalisation. Additionally, continuous assessment of relevant legislation should happen in parallel, to avoid building more barriers.
The performance indicators for the five specific objectives of the programme are quite basic and very much focused on quantity. Especially in the HPC area, the focus seems to be about numbers of machines, rather than quality and what we aim to actually get out of the machines. As for the digital skills, it is positive that this objective is acknowledged, but the performance indicators should include discipline-specific digital skills and more quality-oriented indicators.
The Digital Innovation Hubs (DIHs) have a very central role in the implementation of the programme, with the aim to stimulate the broad adoption of advanced digital technologies by industry, by public organisations and academia. Similar to other EU “innovation-labeled” instruments and programmes (such as the European Innovation Council in Horizon Europe) it is difficult to understand the full picture of the actual work done by the DIHs. The variety and number of activities mentioned as part of the responsibility of the DIHs indicate that there may be too high expectations on the role and capacity of these hubs. How will the DIH in practice attract for instance companies?
CSC - IT Center for Science Ltd. is a non-profit company, owned by the state of Finland and Finnish universities and universities of applied sciences. CSC develops, integrates and offers high-quality ICT services for research, education, culture, public administration and companies.
Read full response6 Aug 2018
CSC welcomes the principles and practices of Open Science as the modus operandi of the programme. It is very positive that Horizon Europe aims to foster open access to research data, supports FAIR principles and the further development of EOSC. More emphasis could however be put on data interoperability and the training and skills development aspect of Open Science.
It remains unclear how the promised coherence between and within the three pillars emerges and how it helps to achieve the program objectives. Especially, the linkage between pillar 1 “Open Science” and pillar 3 “Open Innovation” needs to be described more concretely, since innovations are ultimately based on achievements of basic research. CSC recognizes that the mission-oriented approach is one way to strengthen the link between the pillars, but more interconnection is needed.
It is crucial that more funding is allocated to Pillar 1 “Open Science”, especially to Research Infrastructures (RIs). Pillar 1 has previously shown great European added value, yet compared to H2020, the RI budget decreases 3% (from 2,480 billion to 2,4 billion). Access to RIs has become even more important for both research and innovation, and securing enough funding for RIs is crucial for all science and innovation activities, thus affecting the results within the other pillars as well. RIs are also becoming increasingly advanced and more expensive to develop, which has to be reflected in the funding.
It is encouraging to note that the need to reinforce the international dimension of EU RIs is recognized, and that the international collaboration will be based on excellent science/technology/innovation capacities. Research Infrastructures and e-Infrastructures in particular are global efforts and even more so in the future. What is done in Europe has to comply with other efforts elsewhere. Hence the interoperability aspect and the possibility for Research Infrastructures to become more engaged in addressing multi-layer interoperability issues should be better addressed.
There is no information either in the proposal or in the annexes why the budget is structured the way it is. For transparency, at least the main arguments for the reasoning behind the division of the budget needs to be clearly stated.
CSC recognizes the ambition of the European Innovation Council to enhance the effectiveness of the programme by bridging the gap between research and commercialization, and the implementation of the EIC itself is very well described. Nevertheless, CSC is concerned about the implementation of EIC´s instruments. “Bottom-up activities” seem to be a crucial element both in the workings of Accelerator and Pathfinder, but the meaning of “bottom-up” in this context needs a more precise definition. The idea of EIC being a “one-stop-shop” to high-potential innovators also needs a more concrete explanation.
Excellence should remain the key criterion for the selection and evaluation of missions. It is important to include competences and capacities from a variety of fields, and to involve different actors and stakeholders in the planning of missions. However, the focus of citizen involvement should not be to involve citizens in the choice of missions, but rather on dissemination of the results as well as enhancing citizen science. Since there is no separate budget for the missions, it needs to be more transparent how the funding of the missions actually will be allocated.
CSC - IT Center for Science Ltd. is a non-profit company, owned by the state of Finland and Finnish universities and universities of applied sciences. CSC develops, integrates and offers high-quality ICT services for research, education, culture, public administration and companies.
Read full responseResponse to 2nd Data Package
19 Jan 2018
The free flow of data is crucial for European competitiveness. Europe needs to urgently create a supportive environment as well as a stable and coherent legislative basis for capitalizing on data in creating innovation and growth in Europe. New trends and developments, such as artificial intelligence and platform economy are dependent on data.
However, regulation is not the solution. Europe should avoid building new barriers for data movement. Thus, the need for new regulation should be critically assessed. Instead, active attempts to reduce and harmonize legislation should be made across the Member States. With European legislation we cannot regulate American or Asian actors who already dominate the data-driven markets in Europe – but we only hinder the European data industry. Removing data location restrictions is not enough for creating efficient preconditions for new data-driven business. More focus should be put on ensuring that the data can actually be used. The EC should actively support the re-use of data between different sectors (commercial, academic and public) and interoperability on all levels: legal, organizational, semantic and technical. The European Interoperability Framework should be applied.
Specific focus should be put on semantic interoperability: the ability to exchange and process data in a way that preserves the usability, intelligibility and meaning of data. User-drivenness is essential in building a sustainable data management framework. The benefits of these actions should be visible and tangible for both end-users and stakeholders to ensure successful implementation. Europe should leverage existing work and achievements, such as the outputs of Research Data Alliance (RDA) and the EU ICT Technical Specifications.
EC encourages the development of self-regulatory codes of conduct at EU level in porting data. It is essential to broadly engage different stakeholders. However, this process should not create diverse overlapping or conflicting guidelines that might slow down data flows. Furthermore, information security must be a clear, cross-cutting theme.
In developing the data economy, there should be a strong link to the EC Skills Agenda in terms of analysing data skills requirements and generating solutions. Skills and know-how for data management are urgently needed. EU should systematically invest in developing relevant skills on all education levels and sectors, including teachers’ education.
It is critical that all initiatives under the Digital Single Market strategy are consistent and coherent, in order to avoid a siloed approach where new barriers might be built. All relevant legislation should be analyzed critically and removed if necessary. One dangerous example is the proposed DSM directive, in which the text and data mining (TDM) exception is narrowed only to research organisations for the purposes of scientific research. TDM provides considerable benefits for the European economy and research, it is e.g. a key feature in developing artificial intelligence. European startups need to be supported by a TDM exception that allows for commercial use. If the use of TDM is not fostered and supported in Europe, there is a huge risk of losing the brightest minds and economic benefits.
The European Open Science Cloud (EOSC) will place the seamless flow of data, scientific results and knowledge at the heart of the research and innovation process. All issues discussed in this statement apply to the EOSC context. To make the EOSC a success, Europe should focus on making data FAIR (findable, accessible, interoperable and reusable) within and between scientific disciplines, promoting also data usage between research and industry. EU is investing heavily in building the infrastructure for EOSC, thus it is essential to make sure that no legislative barriers exist. Special attention should be paid on commonly agreed usage of metadata and data management plans as well as data provenance.
Read full responseResponse to Review of ENISA Regulation and laying down a EU ICT security certification and labelling
5 Dec 2017
CSC – IT Center for Science Ltd. (CSC) is a government owned non-profit Finnish center of expertise in ICT developing, integrating and providing services for research, education, culture, public administration, and enterprises. As a key actor of the Finnish research system, CSC’s services include HPC, data centers, data storage, curation, long-term preservation, data analytics, data publication, and data interoperability, as well as software development, network connectivity and research networks, and expert services.
As a national stakeholder on cybersecurity for research, education and IT services for government on both national and European level, CSC exercises its opportunity to give a statement regarding the future roles of ENISA, the EU Cybersecurity Agency.
Most of the current issues on cyber security are generic and cross the borders of member states, whereas common denominators are related to technology and the types of digital services offered. Risks related to cyber security are continually increasing, becoming more advanced and having more potential impact on IT services, and on the resilience of the member states.
Unfortunately, legal frameworks, statues, and operational support from public agencies have not been able to meet the challenges of the increasing threats. Legal frameworks for information security are fragmented, rambling and incompatible between the member states. The role of ENISA has been unclear and ambiguous in terms of information security, providing advice and services to administration, industry and citizens in member states
CSC supports the proposal that clarifies the role of ENISA, and harmonizes as well as develops a common European framework for information security. However, the new role of ENISA must be developed under the European Commission’s careful guidance and that of the member states, to avoid perils of self-absorbed developments.
A trustworthy, agile and efficient European set information security certification could greatly benefit the ability to provide digital services in Europe. An ensured system to define requirements and accredited auditors in the member states should be developed.
Regarding the operational security, CSC considers ENISA to have an appropriate role in creating coherent European level policies and requirements for information security. Currently, the member states have been referred to security guidelines created by and for the United States.
CSC views that the option of creating an operational CSIRT at ENISA could be considered if more information of the scope and mission of such team would be available.
CSC considers that coordinating information security as such is not an adequate mission for a European agency. ENISA should have a clearly defined mission and full operational capabilities to safeguard and secure European digital services.
Read full responseMeeting with Keith Sequeira (Cabinet of Commissioner Carlos Moedas)
5 May 2017 · Open Science
Meeting with Roberto Viola (Director-General Communications Networks, Content and Technology)
6 Sept 2016 · the European collaboration and synergy in HPC and e-infrastructures in general.