Response to the Commission on a European Strategy for Data

FESE supports the strategy of the European Commission in proposing an overarching data strategy that has the potential to achieve the benefits of the single market and avoid further fragmentation. To this end, we believe a harmonised European approach is preferable to speed up the use and investment in technologies and avoid lagging behind other jurisdictions. We consider that regulators possess the appropriate tools to act quickly and effectively to prepare a harmonised approach in the form of legislation. Nevertheless, caution should be exercised and legislation should be designed proportionally to the existing business environment.

It is important not to create disincentives towards data collection/standardisation and product developments, i.e. allowing for commercialisation of data. Considering the above, FESE sees the need for a clear and concise definition of “data” in the form of a classification framework. As such, we would propose the following:

1. Source of data.
2. Ownership of data.
3. Data quality.
4. Data value.
5. Pooling of data.
6. Availability.
7. Timestamp.

Finally, cloud markets offer technological solutions in financial markets to innovate and should be supported. We actively support the EU´s work designing “Voluntary Standard Contract Clauses” to facilitate future negotiations.