PSI Alliance
Representing the public sector information and open data industry, campaigning a fair place for data reuse.
ID: 134928812137-52
Lobbying Activity
16 Apr 2021
Thank you for the opportunity to comment on the planned implementing regulation regarding BRIS data. As a representative of companies that use public sector information, we see a close connection between the BRIS data and the high value data sets according to the PSI Directive.
In Annex I the Open Data and PSI Directive defines “Companies and company ownership” as a category for high value datasets. Member States should provide their business registers or at least core data of their business registers for free in the future. However, re-users that want to use company data on a European wide basis will have the problem to synchronise and align data from 27 Member States, remove duplicates and monitor 27 registers to keep up to date.
By implementing the Business Register Interconnection System the European Commission has already mastered this challenge. The key data
• EUID
• Alternate ID
• Legal form T
• Name
• Registered Office
• Register Name
are available in one searchable and accessible dataset that covers the whole of Europe. According to Regulation (EU) 2015/884 the data are stored in a European Central Platform on the E-Justice Portal.
Data from the BRIS system represent a particularly valuable dataset for transnational PSI applications due to the processing carried out by EC Justice and thus by the European public sector. In the light of the new legal framework some fragments of the Directive EC 1024/2019 come instantly to a re-users mind:
“address the remaining and emerging barriers to a wide re-use of public sector and publicly funded information across the Union”, “increase of the supply of valuable public data for re-use”…, but the key message is found in Recital 13:
One of the principal aims of the establishment of an internal market is the creation of conditions conducive to the development of services and products Union-wide and within Member States. Public sector information or information collected, produced, reproduced, and disseminated within the exercise of a public task or a service of general interest, is an important primary material for digital content products and services and will become an even more important content resource with the development of advanced digital technologies, such as artificial intelligence, distributed ledger technologies and the internet of things. Broad, cross-border geographical coverage will also be essential in that context. Increased possibilities of re-using such information is expected, inter alia, to allow all Union businesses, including microenterprises and SMEs, as well as civil society, to exploit its potential and contribute to economic development and high-quality job creation and protection, especially for the benefit of local communities, and to important societal goals such as accountability and transparency.
It would be a great hurdle especially for smaller companies like SMEs to monitor and collect company data from 27 Member States for pan-European applications. By providing a coherent up to date backbone based on the key- BRIS data the European Commission could foster pan-European applications significantly.
The BRIS data should be released according to the provisions laid down for High Value Datasets in the new PSI directive.
The BRIS system of pan-European searches should also serve as a model for the other thematic categories set out in the High Value Datasets in the PSI and Open Data Directive or to be further added by the Commission in a future delegated act (for example, judicial information).
Read full responseResponse to Implementing act on a list of High-Value Datasets
25 Aug 2020
The PSI Alliance is grateful for the opportunity to comment on the Implementing act on a list of High-Value Datasets. After taking part in the validation workshop at July the 28th we want to outline one key principle of the HVD definition:
We welcome Article 14 of the directive 2019/1024 regarding HVDs, in particular that specific high-value datasets shall be:
(a) available free of charge, subject to paragraphs 3, 4 and 5;
(b) machine readable;
(c) provided via APIs; and
(d) provided as a bulk download, where relevant.
However, we want to remind the Commission and public authorities that all public datasets subject to the revised Open Data Directive are of value and should not be ignored just because they are not classified as a HVD and subject to the Implementing Act.
In particular, we want to highlight that ‘normal’ PSI datasets should also be subject to the following:
Charging
According to Article 6 the re-use of documents shall be free of charge, but recovery of the marginal costs may be allowed.
Machine readable format
Article 5 says that documents shall be made available where possible and appropriate, by electronic means, in formats that are open and machine-readable.
APIs and bulk download
According to Recital 32 and Article 5.5 dynamic data shall be made available via APIs.
During the process of creating the HVD list and especially during the workshop many datasets were mentioned and discussed, but nobody mentioned that to all of these datasets the PSI directive applies directly since 2015. The Member States are obliged to make these datasets reusable, at least following a request, according to Article 4 of the directive. It may be that these datasets are not totally free of charge at the beginning or machine readability is lacking, but at least they should be available for reuse.
Conclusion:
The question regarding all the datasets mentioned in the validation workshop is not whether to release or not to release, but only in which way they should be released, i.e. as HVDs or as “normal” PSI. We urge the European Commission to communicate this fact to the representatives of the Member States.
Read full responseResponse to Legislative framework for the governance of common European data spaces
31 Jul 2020
The PSI Alliance is a European alliance of private companies that reuse public sector information/public open data as a core part of their business model.
We welcome the Common European Data Space initiative. In particular the recognition that there has been a low degree of use made of data held by public sector bodies and that more needs to be done in addition to the Open Data Directive to improve the accessibility of publicly held data.
Data reuse would be greatly aided by ensuring some simple practical arrangements are in place in order to facilitate the search for documents available for re-use, such as asset lists of main datasets, accessible online and in machine-readable format, and having portal sites that are linked to decentralised asset lists. These national portal sites should be compatible with the European Open Data Portal for foster greater pan-European reuse of open data. If we want to improve and increase reuse of open data, businesses and citizens need to be able to find the data in the first place.
Other key barriers are public administrations that want to maximise access fees, and a mindset that public sector bodies defend ‘their’ data and transparency is seen as a threat and not as an opportunity. Public authorities and public undertakings should also support the demand side by ensuring that reusers know about their rights and have effective means of redress in case of rejection of their requests to access open data. Finally, Member States should be required to clamp down on discrimination – it is still commonplace for private re-users not to have access to the same data as state owned competitors.
Read full response