(These comments refer only to the paragraphs within the remit of industriAll European trade union, i.e. Executive Summary, §1,2,3,6 and 7)

General observations on the document

industriAll Europe is satisfied to see that several of the concerns that we had expressed have been included in the document, namely:

• the need for Fair, Reasonable and Non-Discriminatory (FRAND) economic and legal conditions to access industrial digital platforms (§7.2.3, §7.3.3, §7.4.2), as we recommended in our Policy Brief on digital integration of industry, in our Position Paper on digitalisation of industry and in the recommendations of our strategic study on ICT (§2.6.1), and more generally your insistence on the fair distribution of the value being created by industrial digital platforms (Executive Summary, §4.2.1, §4.3.3, §6.3.2, §7.1, §7.4.2, §7.4.3), and on the avoidance of vendor lock-in (§4.4.1, §7.1, §7.3.3, §7.4.2, §7.7.3) and of private monopolies (Executive Summary, §3.3.1, §7.4.2)
• the opportunity presented by the traceability requirements of the Circular Economy to drive the digitalisation of industry and to federate dispersed platforms (§3.1, §3.3.3, §7.2.3, §7.3.1, §7.4.2), as proposed by our Policy Brief on an Industrialised Circular Economy (p.9)
• the mention that worker-related data is a specific issue deserving specific consideration (Executive Summary), and that “access to data by the worker, legitimate processing of data and international transfer of worker-related data (specifically: outside the EU)” should be the purpose of minimum standards (§6.3.3), as we supported in the recommendations of our strategic study on ICT (§3.7)
• the mention that “regulation should effectively protect the interest of workers” (§3.3.3).

We regret however that the intention expressed regarding the prevention of private monopolies on industrial digital platforms does not translate into deeds. Regulation on the nature of the standards allowed on the European market, and the synchronising and coordinating role that the Commission could play to avoid the “penguin effect” (as mentioned in our earlier remarks) are not mentioned.

We are also very critical of the concept of data “ownership”, and would recommend replacing systematically in the document:

• “data ownership” with “rights to access and to process data”
• “data owner” with “data originator”
• the verb “to own” by “to originate” when referring to data.

Specific observations on the document

These specific observations are in addition to any one that would be a consequence of the general observations outlined above. Proposed additions to the text are in bold, proposed removals are [between brackets].

Chapter 3. Overview of the Strategy in "Connected Smart Factories”

§3.1, p.14:  You could add our documents to the list of those supporting the views that “Industry-driven platforms are widely seen as a strategic requirement for Europe to master these new value chains”: IndustriAll European trade union considers the Internet of Things in “locomotive” application markets as a major industrial opportunity to boost European industry’s non-cost competitiveness (footnote: Strategic study on the anticipation of change in the European ICT sector, September 2016)

Chapter 7. Overview of the Strategy in "Internet of Things"

§7.2, p.48: To support this, standards for semantic and format interoperability are needed to connect different [proprietary] platforms (be they proprietary, community-based or open-source) and federate cloud services.