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Insurance Europe also welcomed the acknowledgement by the Commission that sector-specific legislation can add new and complementary elements to this data framework, such as the envisaged legislation on the European health data space and on access to vehicle data.
At the same time, the insurance industry supports the overall approach set out in the Commission’s data strategy, which recognises that sector-specific legislation on data-sharing should only be introduced where there are identified market failures; the focus should otherwise be on strengthening the conditions for data collaboration and data partnerships.
There should also be greater clarity regarding the nature of the data sharing services that fall within the scope of the proposed Regulation. While the Commission’s proposals offer some important clarifications in this regard, this could be made more explicit through the provision of concrete examples.
The proposed rules also need to be designed in a way that fully complies with all data protection requirements, and that ensures that data subjects remain fully in control of their data and can freely choose between different providers.