Position Paper Bitkom views concerning the Presidency´s Discussion Papers and the latest developments regarding the ePrivacy Regulation
The latest Presidency Papers and developments in the WP TELE and DAPIX meetings regarding the ePrivacy Regulation have shown a need for more discussions on certain aspects of the Proposal. Bitkom welcomes the Presidency´s approach to the issues in considering different options for the relevant provisions. Bitkom urges the Presidency to consider issues regarding the scope and application of the ePrivacy provisions. We need alignment with the GDPR and the EECC and an amendment of the scope regarding M2M communication. Technical feasibility should be discussed in depth, especially with regard to Article 8 and 10. Regarding permitted processing under Article 6, the Presidency comments on the possibility to include the GDPR legal basis of “legitimate interests” and “further processing” for compatible purposes. Article 15 ePR needs to be amended to include the phrase “operators of electronic communication services”. All aspects are discussed in detail in our latest position paper, which you can download here.