Regulatory environment for platforms, online intermediaries, data and cloud computing and the collaborative economy

Bitkom welcomes the opportunity to contribute to the public consultation on the regulatory environment for platforms, online intermediaries, data and cloud computing and the collaborative economy, as we believe that these issues deserve in-depth consultation with all parties involved and analysis before rushing into any legislative action.
However, we would like to outline the difficulties we encountered in trying to respond to the questionnaire built by the European Commission. We regret, for instance, that sections for comments were not made available for every question of the consultation as such availability depended on the answer given – yes or no. This constitutes a missed opportunity for respondents to explain their position as well as for the European Commission to understand the context and the reasons why a specific position is taken. We also regret the phrasing of many questions, for which we see a degree of bias that will result in misleading answers from the respondents. Finally, the questionnaire lists a selection of assumed practices of platforms – Section IV of the first of part of the consultation - out of context and in isolation from each other.
This version slightly differs from the version we have submitted to the Commission. It shows the answers Bitkom would have given without the problems mentioned above.