Mozilla recently submitted our response to the European Commission’s public consultation on its European Strategy for Data. The Commission’s data strategy is one of the pillars of its tech strategy, which was published in early 2020 (more on that here). To European policymakers, promoting proper use and management of data can play a key role in a modern industrial policy, particularly as it can provide a general basis for insights and innovations that advance the public interest.
Our recommendations provide insights on how to manage data in a way that protects the rights of individuals, maintains trust, and allows for innovation. In addition to highlighting some of Mozilla’s practices and policies which underscore our commitment to ethical data and working in the open – such as our Lean Data Practices Toolkit, the Data Stewardship Program, and the Firefox Public Data Report – our key recommendations for the European Commission are the following:
- Address collective harms: In order to foster the development of data ecosystems where data can be leveraged to serve collective benefits, legal and policy frameworks must also reflect an understanding of potential collective harms arising from abusive data practices and how to mitigate them.
- Empower users: While enhancing data literacy is a laudable objective, data literacy is not a silver bullet in mitigating the risks and harms that would emerge in an unbridled data economy. Data literacy – i.e. the ability to understand, assess, and ultimately choose between certain data-driven market offerings – is effective only if there is actually meaningful choice of privacy-respecting goods and services for consumers. Creating the conditions for privacy-respecting goods and services to thrive should be a key objective of the strategy.
- Explore data stewardship models (with caution): We welcome the Commission’s exploration of novel means of data governance and management. We believe data trusts and other models and structures of data governance may hold promise. However, there are a range of challenges and complexities associated with the concept that will require careful navigation in order for new data governance structures to meaningfully improve the state of data management and to serve as the foundation for a truly ethical and trustworthy data ecosystem.
We’ll continue to build out our thinking on these recommendations, and will work with the European Commission and other stakeholders to make them a reality in the EU data strategy. For now, you can find our full submission here.