02 July 2018
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The letter is the latest in a long line of concerns raised by EU data protection specialists, such as the European Data Protection Supervisor and the EU's Fundamental Rights Agency.
The letter notes that the term "interoperability" is in itself "misleading" because the "purpose of the proposed regulations is the effective interconnection of the aforementioned information systems," which "represents a major change in the information systems design and, consequently in the way personal data is processed at European and national levels."
It is "unfortunate", says the letter, that "discussions on this complex process were rushed" - they are currently ongoing - and highlights the problematic fact that the Commission has failed to "demonstrate the extent of the problem of identity fraud among third-country nationals," one of the key issues that "interoperability" is supposed to address.
The letter also calls for more resources for data protection bodies so that they can carry out their work effectively, supports previous opinions issued by the European Data Protection Supervisor, Fundamental Rights Agency and the Article 29 Working Party and makes a number of specific recommendations on the proposals for Regulations.
See: Chairs of the SIS II, VIS and Eurodac Supervision Coordination Groups: Opinion on the Proposals for two Regulations establishing a framework for interoperability between EU large-scale information systems (10484/18, 27 June 2018, pdf)
Fundamental Rights Agency: Interoperability and fundamental rights implications (11 April 2018, pdf)
Article 29 Working Party: Opinion on Commission proposals on establishing a framework for interoperability between EU information systems in the field of borders and visa as well as police and judicial cooperation, asylum and migration (11 April 2018, pdf)
Statewatch Analysis: The Point of no return: Interoperability morphs into the creation of a Big Brother centralised EU state database including all existing and future Justice and Home Affairs databases (pdf)
Proposals available here:
Plans to link all Justice & Home Affairs databases into one
(17 December 2017)
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