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[ NNSquad ] EU privacy czar against ACTA




Begin forwarded message:

> From: Richard Forno <rforno@infowarrior.org>
> Date: February 22, 2010 10:45:56 AM EST
> To: Undisclosed-recipients: <>;
> Cc: Dave Farber <dave@farber.net>
> Subject: EU privacy czar against ACTA
>

> EU Data Protection Supervisor Warns Against ACTA, Calls 3 Strikes  
> Disproportionate
>
> Monday February 22, 2010
>
> http://www.michaelgeist.ca/content/view/4809/125/
>
> Peter Hustinx, the European Data Protection Supervisor, has issued a  
> 20-page opinion expressing concern about ACTA.  The opinion is a  
> must-read and points to the prospect of other privacy commissioners  
> speaking out.  Moreover, with the French HADOPI three strikes law  
> currently held up by its data protection commissioner, it raises  
> questions about whether that law will pass muster under French privacy 
> rules.
>
> Given the secrecy associated with the process, the opinion addresses  
> possible outcomes based on the information currently available.  The  
> opinion focuses on three key issues: three strikes legislation,  
> cross-border data sharing as part of enforcement initiatives, and  
> transparency.
>
> Three Strikes
>
> On three strikes, the opinion begins by noting the privacy  
> implications:
>
> Such practices are highly invasive in the individuals' private sphere. 
> They entail the generalised monitoring of Internet users’ activities, 
> including perfectly lawful ones. They affect millions of law-abiding 
> Internet users, including many children and adolescents. They are 
> carried out by private parties, not by law enforcement authorities. 
> Moreover, nowadays, Internet plays a central role in almost all aspects 
> of modern life, thus, the effects of disconnecting Internet access may 
> be enormous, cutting individuals off from work, culture, eGoverment 
> applications, etc.
>
> The opinion then assesses three strikes within the context of European 
> data protection law, concluding that it is a disproportionate measure:
>
> Although the EDPS acknowledges the importance of enforcing intellectual 
> property rights, he takes the view that a three strikes Internet 
> disconnection policy as currently known - involving certain elements of 
> general application - constitutes a disproportionate measure and can 
> therefore not be considered as a necessary measure. The EDPS is 
> furthermore convinced that alternative, less intrusive solutions exist 
> or that the envisaged policies can be performed in a less intrusive 
> manner or with a more limited scope. Also on a more detailed legal level 
> the three strikes approach poses problems.
>
> Among the specific problems, Hustinx concludes that the benefits simply 
> don't outweigh the costs:
>
> The EDPS is not convinced that the benefits of the measures outweigh  
> the impact on the fundamental rights of individuals. The protection of 
> copyright is an interest of right holders and of society. However, the 
> limitations on the fundamental rights do not seem justified, if one 
> balances the gravity of the interference, i.e. the scale of the privacy 
> intrusion as highlighted by the above elements, with the expected 
> benefits, deterring the infringement of intellectual property rights 
> involving - for a great part - small scale intellectual property 
> infringements.
>
> Data Sharing
>
> The opinion also considers the privacy implications of data sharing  
> arrangements facilitated by ACTA for enforcement purposes:
>
> It can be questioned first whether data transfers to third countries in 
> the context of ACTA are legitimate. The relevance of adopting measures 
> at international level in that field can be questioned as long as there 
> is no agreement within the EU member states over the harmonisation of 
> enforcement measures in the digital environment and the types of 
> criminal sanctions to be applied. In view of the above, it appears that 
> the principles of necessity and proportionality of the data transfers 
> under ACTA would be more easily met if the agreement was expressly 
> limited to fighting the most serious IPR infringement offences, instead 
> of allowing for bulk data transfers  relating to any suspicions of IPR 
> infringements. This will require defining precisely the scope of what 
> constitutes the 'most serious IPR infringement offences' for which data 
> transfers may occur.
>
> The opinion follows this with detailed recommendations on how ACTA can 
> facilitate sharing of information and ensure appropriate privacy  
> safeguards.
>
> Transparency
>
> Hustinx is direct and to the point on the issue of transparency:
>
> The EDPS strongly encourages the European Commission to establish a  
> public and transparent dialogue on ACTA, possibly by means of a public 
> consultation, which would also help ensuring that the measures to be 
> adopted are compliant with EU privacy and data protection law 
> requirements.
>



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