We will make these more detailed comments as we find time during the consultation period. For the sake of our users' privacy the GPA urges the European Commission to provide a proper public dialogue before proposing any substantial revision. In brief, we urge the Commission to: Make appropriate provision for data portability — as an essential precondition for the full application of this Regulation with meaningful effects; and Ensure broad access to such information by individuals; and To create a uniform information sharing approach, including a mechanism for developing an EU-wide rules of confidentiality, which is the basis for the privacy framework in other countries. The GPA believes that sufficient scope must be given to individual rights and freedoms in the scope of surveillance methods employed, the collection and processing of personal data and the storage of such data, while also ensuring adequate legislative, administrative and judicial guarantees of confidentiality. The GPA further notes the lack of meaningful transparency into the actual implementation of these regulatory provisions by the EU legislative bodies for many years. The GPA is concerned that the current situation leaves too much room for public debate on the implementation of Regulation (EC) No 552/2008, while ensuring sufficient security in the application of the data protection rules. The GPA remains fully committed to taking a constructive role in the European Commission s consultation on the regulation. The GPA appreciates the effort that the new President of the European Commission, José Manuel Barros, has made addressing privacy issues and hopes that continued engagement will be fruitful.
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Submission from the Global Privacy Alliance (GPA) to the European Commission s Communication on A comprehensive approach to personal data protection The Global Privacy Alliance (GPA) welcomes the
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