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Bitkom welcomes the opportunity to comment on the European Data Protection Board’s (EDPB) draft Guidelines on the interplay of the Second Payment Services Directive and the GDPR (EDPB Guidelines). We believe that more cooperation and exchange between data protection authorities and practitioners is needed to translate the legal text of the GDPR into practice and reduce legal uncertainty, especially in the context of the interplay with the Second Payment Services Directive (PSD2) as well as with other legislation.

The German Presidency has recently published an Option Paper for further discussions on the proposed ePrivacy Regulation. While we welcome some of the proposed options, Bitkom still has concerns about the e-Privacy proposal (see here for our previous Position Papers). The EU Commission's goal of 'better regulation' is still not reflected in the option paper currently on the table and drafted by the German presidency.

Recently, the EU published the EU Data Strategy and invited stakeholders for feedback. We welcome this opportunity and the consultation for the Data Strategy, and support the idea that the European Union needs an overarching data strategy in order to achieve the benefits of the Single Market and avoid fragmentation.

Cross-border data flows between the U.S. and Europe are the largest in the world and are fundamental to the largest trading relationship in the world, valued at approximately 1.3 trillion U.S. dollars annually. Transatlantic data flows account for over one-half of Europe’s data flows and about half of U.S. data flows.