Thread by @wavesblog

Reading Schwab's compromise amendments (Amazon/Apple later, @SebastianLouven ) - an hidden pearl is that "The Commission may also ask one or more competent national authorities to support its market investigation" - also a DPA, of course 🙂

Missing comma between health tracking and financial services (intriguing Recital 64)

And how not to love the possibility of interim measures "where a risk of serious and immediate damage for business users or end-users of gatekeepers could result from new practices that may undermine contestability of core platform services"?

But why not in case of unfair practices (from my @dieLinke Report)?

Explicit consent as of Art. 5a - enough? See the brand new Kerber/Specht Report vzbv.de/sites/default/…

Good for the narrow MFN extension - what else? papers.ssrn.com/sol3/papers.cf…

An impressive data protection defence in Art. 5 ca...

5e: *or any other ancillary service*

Ancillary services extensions as of Art. 5ga also much appreciated

I actually wrote it in the @dieLinke Study too 😎 ( I thought I might have forgotten it)

"Combining data +" for targeted or micro-targeted advertising 👉"a clear, explicit, renewed, informed" (compare with "explicit and clear manner")

"undermine end-user data protection" : necessary and proportionate measures justified by the gatekeeper (good interplay with DP essential)

There are actually (at least) *3* interoperability-related obligations 🙂 ((f) needs some minor editing - perhaps)

In-situ access "at the request of the business user"

Merger info received by "competent national authorities" may be used in merger control assessment - important clarification

...the @EU_EDPS explicitly mentioned! ("The Commission shall develop, in consultation with the EU Data Protection Supervisor, the European Data Protection Board, civil society and experts, the standards and procedure of the audit" of profiling techniques)

"gatekeeper shall implement effective measures to ensure its compliance with the obligations laid down in Articles 5 and 6, and shall
*demonstrate that compliance, when called upon to do so*" (the "by design" spirit)

✅

"The Commission may decide to invite interested third parties to submit their observations within a time limit" it should the norm, if you ask me ;-)

Guidelines, yes! "where the Commission deems that this is appropriate. Where appropriate and necessary, the Commission may mandate the standardisation bodies to facilitate the implementation of the obligations by developping appropriate standards"

Important: "as with accessibility requirements for the persons with disabilities"

The compliance function 🙂

Last but not least: "European High-Level Group of Digital Regulators" "competent authorities and representatives of other national competent authorities in specific sectors"

"National competition authorities as well as other competent authorities designated by
the Member State shall support the Commission in monitoring compliance with and enforcement of the obligations laid down in this Regulation and report regularly to the Commission on compliance"

"National competition authorities as well as other competent authorities may collect
complaints in accordance with the procedure foreseen in Article 24a."

⛔️19a and others: "the Commission within those 60 days" can indicate "to the national authority concerned that the draft measure runs counter to this Regulation or to a decision adopted by the Commission under this Regulation or contemplated in proceedings initiated.."

Much to praise and discuss /END

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