To: European Commission

Making globally harmonized rules to enable secure data use across national borders is indispensable for the high-level utilization of digital technology and data by the international community to promote economic growth and resolve social issues. In this process, policymakers of all countries must adopt the perspective of building a mechanism for the free flow of data aimed at promoting innovation under a clearly defined and consistent system.

From this standpoint, we support the goal of expanding data utilization under the "カジノシークレット おすすめ ゲームernance Act" proposed by the European Commission on Nov. 25, 2020 and would like to make the following comments.

P.15 (19)

• When considering rules on the use of non-personal data in the health care sector, flexible use of data through cooperation with countries outside the EU should be allowed in an emergency, such as the Covid-19 pandemic.

Chapter 2
Article 5 Conditions for re-use
P.26 (3)-(5)

• EU member states should have common rules in order to prevent a situation in which different obligations are imposed by different countries on data re-use by companies.

P.27 (9)-(10)

• Obligations of third country re-users of transferred カジノシークレット おすすめ ゲームhould be clarified further and rules that do not overly restrict data transfer should be made through discussions by various stakeholders.
• Discussions should take place for the early institution of a data transfer system between Japan and the EU through such forums as the Japan-EU Committee on Regulatory Cooperation.
• Rulemaking on the transfer of non-personal data to third countries should be considered in a manner totally separate from rules on the transfer of personal data to third countries.

P.27 (11)

• The scope of カジノシークレット おすすめ ゲームuot;highly sensitiveカジノシークレット おすすめ ゲームuot; data should be clearly defined based on discussions among various stakeholders
• Stricter conditions for the transfer of カジノシークレット おすすめ ゲームuot;highly sensitiveカジノシークレット おすすめ ゲームuot; data to third countries must not virtually prohibit the transfer of such data.

Chapter 3
Article 9 Providers of カジノシークレット おすすめ ゲームharing services
P.29-30 (1)

• カジノシークレット おすすめ ゲームuot;Data sharing servicesカジノシークレット おすすめ ゲームuot; should be defined more clearly based on a broad range of opinions from the stakeholders involved with B2B and B2C data sharing.