Software & Information Industry Association
SIIA
SIIA is a principal trade association for companies in the business of information.
ID: 632689945691-83
Lobbying Activity
Response to EU Space Law: Union law for safe, secure and sustainable space activities
7 Nov 2025
Please see the attached feedback from the Software & Information Industry Association.
Read full responseResponse to Digital package – digital omnibus
14 Oct 2025
Dear DG CONNECT: Please find attached feedback from the Software & Information Industry Association (SIIA), focused on simplification and clarification of the AI Act as it applies to educational technology.
Read full responseResponse to Improving the provision of digital skills in education and training
15 Sept 2022
SIIA strongly supports the proposal for a Council Recommendation on improving the provision of digital skills in education. Please see the attached document.
Read full responseResponse to Enabling factors for digital education
15 Sept 2022
The Software and Information Industry Association (SIIA) appreciates the opportunity to offer comments in relation to a call for evidence on Digital Education – enabling factors for success. Please see the attached document.
Read full responseResponse to Data Act (including the review of the Directive 96/9/EC on the legal protection of databases)
13 May 2022
SIIA appreciates the opportunity to provide feedback on the proposed Data Act. SIIA represents over 450 companies reflecting the breadth of the data-driven economy, many of which are based in the EU and most of which do business in the EU.
Summary. SIIA supports the objectives of the Act to unlock the innovative value of data while ensuring responsible practices for its use, collection, and sharing. Despite laudable intentions, the Act impedes business efforts to innovate and compete in a data-driven economy and imposes barriers on responsible data use. Certain provisions would increase compliance costs and impose barriers to commercial contracting that will hurt innovation and competition. Limited protection for intellectual property (IP) and trade secrets will limit incentives to innovate. Contrary to the objective of data minimisation, several provisions would lead businesses to create more rather than less data, increasing cybersecurity risk and personal data exposure. We therefore offer the following recommendations, which we address in further detail in the attached paper.
1. Limit Scope to Non-Personal Data. The term “data” is indiscriminately used throughout the text for both personal and non-personal data. This ambiguity will confuse both businesses and consumers and generate significant implementation challenges. Limiting the Act to non-personal data will improve workability, avoid clear conflicts with GDPR, and mitigate privacy and security risks.
2. Minimize B2C Privacy and Security Risks. We recommend excluding diagnostic and other non-structured data and virtual assistants. In most cases, compliance would require businesses to generate data in new formats to accommodate user requests, undermining data minimisation while creating security and privacy risks.
3. Protect Contractual Freedom. Contractual certainty and flexibility allow SIIA’s members to ensure appropriate use of data, protect IP and trade secrets, and remedy breach. The Act should strengthen deference to contractual relations in Arts. 3(2), 4 and 5 and permit business parties to negotiate the terms of data sharing in most situations. In addition, Art. 13 should give SMEs more flexibility to enter into private contracts.
4. Strengthen Protections for IP. The term “data” expressly covers almost all manifestations of protected material, and the software and database industries have both relied on both trade secret and copyright protection to incentivize innovation. Legally, computer programs are “data” and are protected by copyright law–as are databases that are original in their selection, coordination and arrangement–and copyright law places limits on the purposes for which both kinds of works may be used. Compelled disclosure of this kind of information will disincentivize EU firms from innovating. To avoid unintended consequences, the Act should exclude computer programs or data containing trade secrets from Arts. 4, 23 and 24. Similarly, Art. 35 should clarify that the Act does not expand or contract copyright protection in any selection, coordination or arrangement.
5. Provide Safeguards around B2G Data Sharing in Arts. 14-16. We generally support B2G data sharing in situations of “exceptional need” but remain concerned about the potential misuse of the authorities in Arts. 14-16 and conflict with other fundamental EU and member state rights and rules. The Act should include safeguards to protect personal and proprietary information.
6. Eliminate Art. 27’s Restriction on International Transfers of Non-Personal Data. The presumption against transferring data outside of the EU will have drastic effects on the EU economy, SME growth, and EU consumer welfare, vastly exceeding GDPR’s restrictions.
7. Interoperability Standards. Art. 29 should incentivize adoption of industry-developed and international standards.
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