ICC Document & publication

ICC comments on EU General Data Protection Regulation Issues

The following ICC comments deal with on-going EU Data Protection Regulation matters relevant to related future discussions by the European Parliament and the European Council.

The three points outlined in this paper represent specific points of the EU General Data Protection Regulation that raise concern among global business: International Data Flows/Transfers, Administrative Burdens and Harmonization. ICC aims to provide recommendations for improvement of those. ICC likely will have further comments in the future. 

The language in the Regulation proposal is currently in the process of modification, and while these ICC comments reflect the European Commission proposal available at this time, they should also be relevant to conversations of proposed amendments in the future.

This Regulation creates a unique opportunity to promote economic development across the European Union while furthering shared goals of protecting privacy. Predictability in how organizations will process personal data can drive trust and confidence in participation in the digital economy. However, the revised draft does not fully take advantage of the opportunity for clarity. Instead, it runs the risk of creating greater uncertainty, which could decrease investment in the European Union and weaken competitiveness. We urge the European Commission, the European Council and the European Parliament to look specifically at language to provide more clarity for decreasing the burdens on international data transfers, reducing counter-productive administrative burdens, and promoting harmonization.