COCIR welcomes the opportunity to provide feedback to the European Commission’s inception impact assessment for a Data Act. COCIR fully endorses the Commission’s view that the availability of and access to data holds immense potential for innovation and value creation, and that this will greatly contribute to the recovery and resilience of our society following the COVID-19 pandemic.

Representing the health technology and innovation sector, COCIR is strongly convinced of the positive effects of the use of health data in the public interest. The Data Act can be a valuable tool, complementing other existing frameworks in support of a European Single Market for data and the creation of a European Health Data Space.

COCIR would like to emphasise following aspects

-    Coherence should be ensured with ongoing initiatives and existing frameworks
-    Sharing mechanisms should take full advantage of automated means to share and exchange data (e.g. bulk transfers, APIs)
-    Contractual fairness and clarity should be elemental to any business-to-business agreement
-    Rules on data access and usage rights should be fair, reasonable, proportionate, transparent and non-discriminatory use of terms
-    A strengthened framework for cloud services is required to offer European industry the infrastructure and services needed to develop new insights and technologies.
-    Practical rules on data sharing and free flow of data between trusted parties (also non-EU) should remain the general principle

COCIR remains fully committed to working with the European Institutions, the Member States and other involved stakeholders in creating a robust European data economy that will foster a competitive and innovative environment, leading to a stronger and more resilient EU economy and society.