EFK, Alm.del - 2015-16 - Bilag 357: Regeringens høringssvar om en kommende revision af European Interoperability Strategy og European Interoperability Framework

Energi-, Forsynings- og Klimaudvalget 2015-16
EFK Alm.del Bilag 357
Offentligt

Note

Public consultation on the revision of the European Interoperability

Strategy (EIS) and the European Interoperability Framework (EIF):

Danish comments

General comments

29 June 2016

J.no. 2016 - 1365

Denmark recognises the importance of the European Interoperability Strategy

(EIS) and the accompanying European Interoperability Framework (EIF). They

have been a valuable reference framework for national digitisation activities and

the aim of ensuring that basic interoperability considerations are taken into

account as an integrated part of the design and development phases of public

digital services in the Member States.

Denmark finds the Commission’s work on interoperability as valuable and

necessary in the light of the overarching political goals in the Commission

communication on the Digital Single Market endorsed politically by the

Council. In this light, Denmark welcomes the proposed revision of the current

Commission communications on the EIS and EIF from 2010 in order to more

strongly reflect the new political goals and contextual prerequisites, and

creating at stronger linkage to the EU eGovernment Action Plan 2016-2020

(COM(2016) 179 final). In general, Denmark welcomes a better integration of

the principles mentioned in the EU eGovernment Action Plan 2016-2020 and

the proposed revision of EIS/EIF.

Denmark is in favour of the proposed “Option 2” (“Give guidance on

interoperability”). Denmark acknowledges the need to consider different tools

within “soft legislative approaches” and acknowledges the possibility of using

Commission recommendations within identified and commonly agreed (among

Member States) areas of action as a means to guide the Member States.

It is of importance for Denmark, that the EIS/EIF is a basic guiding framework

for Member States to consult and in general comply with, without jeopardising

each Member State’s possibility to consider the use of the framework in the

light of specific needs, purposes, economic and organisational considerations,

and national prioritisations. Denmark finds it of importance to ensure that the

application of the framework is to decrease administrative burden and to enable

Member States making the public sector as a whole more efficient and

effective, and to realise qualitative and quantitative benefits including

cost-savings where possible.

EFK, Alm.del - 2015-16 - Bilag 357: Regeringens høringssvar om en kommende revision af European Interoperability Strategy og European Interoperability Framework

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Specific comments



Definition of “European public service”:

Denmark acknowledges that an European

or a national interoperability framework generally should have a wide

coverage. At the same time it should be made clear, that focus on compliance

of a specific service with a specific recommendation,

e.g.

multilingualism, first

and foremost should be on core public services which have a concrete and

well-defined relevance, user need and a sound business case. This is important

in order to get a wide acceptance and practical use of the framework.



Reuse where possible:

Denmark suggests a general recommendation on “reuse

where possible” regarding solutions, components, and information and data.

Especially the reuse of data could be more clearly recommended as it holds

much potential both in relation to the realisation of a “once-only” principle,

greater efficiency and effectiveness and reduction of administrative burdens

for businesses, and significant quality improvements of public services. In

addition, such a recommendation would also be in compliance with the

principles developed for the EU eGovernment Action Plan 2016-2020.



Directive on accessibility of public sector bodies’ websites:

Denmark suggests replacing

the current communication’s elaborated text on accessibility with a general

reference to the coming Directive on accessibility of public sector bodies’

websites and the application of the standard EN 310 549. Further, it should be

considered how apps could be included in the context of EIS/EIF.



Multilingualism:

Denmark recognises the basic principle of multilingualism, but

in practice the demand for multilingualism is limited. Most linguistic demands

can be satisfied through an English language option in selected solutions.

Therefore, Denmark prefers to have a recommendation which takes into

account the demand dimension and the practical needs in each Member State

as well as the business demands for a digital open market. It could be

considered whether an “on-demand” principle for multilingualism could be

considered instead of a general recommendation covering everything. This

“on-demand” principle should take into account the business case in

relation to public administration and businesses’ gains and burdens in order to

secure economic sound priorities in the public sector as well as at the societal

level including also growth potentials. A shortlist of most needed and

recommended core public services to be supplied in English could be a help

to assist Member States in making priorities. It should be voluntary to comply

with and not directly as part of the EIF.



Security and privacy:

Denmark recognises the need for having a secure digital

environment which protects personal or critical data and each citizen’s privacy

and businesses’ critical business information according to legal requirements.

ICT security and privacy considerations should be taken into account in the

design phase of digital solutions as also mentioned in the EU eGovernment

EFK, Alm.del - 2015-16 - Bilag 357: Regeringens høringssvar om en kommende revision af European Interoperability Strategy og European Interoperability Framework

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Action Plan 2016-2020.



Open data:

Denmark supports a stronger focus on interoperability of data and

registers as also mentioned in a number of initiatives in the Digital Single

Market communication. In this light, Denmark sees possible

recommendations in the area focusing on how better enlarging and deepening

the usage of the PSI Directive as a basis for opening-up public sector

information and data. Denmark supports the removal of barriers for free data

flows and the creation of an infrastructure that makes it easy for interested

citizens and businesses to access information and data, taking into account the

necessary protection of personal data and privacy subject to current legal

requirements.



Standards:

Denmark supports further European standardisation efforts in order

to ensure that interoperability is based on common European standards.

However, Denmark finds it important to ensure that European

standardisation does not slowdown the effort to provide interoperable digital

solutions in the public sector of Member States, and that recommendations on

the choice and use of standards are sufficiently dynamic and flexible that

interoperability can be achieved through multilateral means if common

European means are not available or usable.