kom (2021) 0118 - Bilag 2: Notat samt høringssvar vedrørende digitale principper

Europaudvalget 2020-21
KOM (2021) 0118 Bilag 2
Offentligt

The Danish Government’s response to the public consultation on a set

of European Digital Principles

General comments

The Danish Government welcomes the broad and inclusive debate concern-

ing a set of European Digital Principles. The acceleration of digitalization

is vital for our economic and societal development, security and safety

which Covid-19 has further underlined. At the same time, digitalization and

disruptive technologies also give rise to new risks and scenarios, which

challenge or can even undermine our democratic rights and societies. These

cannot be left unaddressed, as we otherwise risk that the digitalization does

not work in our favor and that trust and security will decrease. Therefore,

we must address those risks and scenarios in order to achieve a human-

centric, responsible and secure digital society.

With the digital principles, we can establish a common understanding of

our European way in our digital single market. A European way where we

form the digital society in our favor, so that it protects and empowers citi-

zens and businesses, underpins innovation and progress in our society as

well as respects our values and rights.

In this context, it is imperative to emphasize that existing rights are valid

offline as well as online. Therefore, the establishment of a set of European

digital principles should not replace existing rights nor create new rights,

as this could question the validity of the EU’s Charter of Fundamental

Rights as well as other international human rights. Instead, the sole objec-

tive of the European digital principles should be to identify the new chal-

lenges stemming from digitalization and to ensure and to promote how ex-

isting rights can be fully exercised and enforced in the digital sphere.

The principles should steer the overall direction in this long-term quest;

meaning that the principles should give direction both here in 2021 as well

as in 2031. This calls for principles which are forward-looking, technology

neutral and descriptive. They should concisely describe the end goal, but

not the specific technique, measure nor method as to achieve such goal.

The selection of concrete policy choices to implement and integrate such

principles should entirely be carried out through legislative procedures.

Overall, the initial themes identified by the Commission cover important

components of our digital society and economy. At the same time, it is es-

sential that we set out our overall vision, meaning how we want to develop

innovative and secure digitalization and what we want to achieve before

addressing these specific components.

Specific comments

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Clear reflection of the green transition

The transition to a sustainable and climate-neutral society is

–

together with

the digital transformation

–

a key priority for the EU. Therefore, it is para-

mount that this aspect is clearly reflected in the principles

–

both in terms

of a digital transformation, which itself is energy-efficient, but also to pro-

mote the development and usage of technologies to reduce pollution, to

improve energy efficiency, facilitate the circular economy etc.

Cybersecurity as a prerequisite to digitalization

A digital society is a vulnerable society unless cybersecurity is made an

integral and active part of digitalization. It is only a question of time before

the next serious cyberattack targets us. The expected increased uptake of

modern technologies will at the same time increase the attack surface

against our democracies, companies and citizens. Therefore, we must en-

sure that a high level of cybersecurity underpins our digital society.

Universal service is already part of existing law

All European citizens and businesses should have access to an internet ser-

vice and the internet should be free and open in accordance with the prin-

ciple of net neutrality. Roll-out of connectivity should be market driven and

regulation should be technology neutral. However, these principles are al-

ready part of EU law such as the Electronic Communications Code and the

regulation on net neutrality. Therefore, we are not immediately convinced

of the added value of also including them in a set of European Digital Prin-

ciples.

Paving the way for innovation and new business models

The transformation to a data-based economy with the use of digital tech-

nologies and services is an important driving force for future growth and

sustainable development. To facilitate such transformation, we must estab-

lish a genuinely digital single market with framework conditions which are

innovation-friendly, digital by default as well as technology neutral.

Thereby, we can encourage new cross-border development as well as a

scaling-up of new business models.

The digital transformation of SMEs

It is crucial that SMEs are able to take advantage of this transformation.

Amongst other things, this implies better access to public and private data

and better opportunities to share their business data relevant actors in a se-

cure, simple and transparent manner. Therefore, it is important that the

principle on human-centric digital public services contributes to promote

more accessible, interoperable and user-driven digital services, thereby,

making life easier for the SMEs.

Accessible and human-centric digital public services and administration

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As society becomes increasingly digitized, it is important to ensure that no

citizens are left behind. This includes designing digital public services to

be accessible to citizens with special needs, in close collaboration with rel-

evant interest organisations. However, we also encourage the Commission

to bear in mind that accessibility also entails making sure that non-digital

citizens have the right to be exempt from the use of digital public solutions

and are presented with alternative or analogue solutions.

With these points, we stand ready to engage in the discussions actively and

constructively on a set of European Digital Principles. Furthermore, we re-

serve the right to submit further comments at a later stage.