Dear David,
Once again, many thanks for going through the draft paper. You were part of our discussions with Leanne, guided us during the process and contributed to the paper, so I think you should share co-authorship
of this piece.
I removed the comments, accepted track changes and made some edits. As you can’t see them immediately in the document, I will summarise them here:
- I left the term EU legislator but added an additional explanation in a footnote (see footnote 19) pointing out the three co-legislating institutions:
EC, EP, the Council. I think of a term ‘the EU legislator’ as a synonym to ‘the EU legislative procedure’.
- I understand why you suggested to replace ‘enforcement’ with ‘governance’ but I do not agree with this suggestion. I went back to scholars
on regulatory theories and several of them suggest that enforcement includes both compliance (soft enforcement) and deterrence approaches (hard enforcement). I stand by this idea, so I added a footnote explaining this view (see footnote 14).
- You questioned what is meant by the role of the leader, it comes from the writing of Hielke and others, where it is suggested that awareness
raising tasks fall within the scope of this role.
- You questioned the need to have a section describing survey methodology. I wouldn’t add it to the paper but I included a reference to it in
a footnote.
- I added a definition of SME Association: Within the scope of this article we use a term SME Associations to refer to different types of organisations
that provide a meaningful support, advice, guidance and training services to SMEs on their functioning, ranging from trade and sectoral associations to chambers of commerce. They can be financed through membership fees or through public sources of funding.
- The following statement was added to explain why we haven’t judged the quality of such guidance. Think about it as a disclaimer: The perception
of these guidelines and their usefulness was not explored within the scope of STAR II questions because originally more narrow focus was placed on the relationship between DPAs and SMEs directly, before the potential for the role of SME Associations emerged.
- I really like the idea of
DPAs and SME associations co-creating guidance for SMEs.
- I didn’t add info about projects mentioned at the end of the paper as there are links provided to their websites.
- Instead ‘of good quality compliance advice’, I opted in for ‘an improved quality compliance advice’.
If you are ok with this, I will send it over to the EDPL.
Looking forward to your reply!
Best regards,
Lina
From: Lina JASMONTAITE <Lina.Jasmontaite@vub.be>
Sent: 18 March 2020 13:57
To: David Barnard-Wills <David.Barnard-Wills@trilateralresearch.com>
Cc: Alessandra Calvi <Alessandra.Calvi@vub.be>; Leanne Cochrane <leanne.cochrane@trilateralresearch.com>
Subject: RE: Star II - publication for WP5
Hi David,
Attached is the last version of it.
Any comments and suggestions are very much appreciated.
Perhaps, there’s sth that we forgot.
Best regards,
Lina
From: David Barnard-Wills <David.Barnard-Wills@trilateralresearch.com>
Sent: Wednesday, March 18, 2020 10:57 AM
To: Lina JASMONTAITE <Lina.Jasmontaite@vub.be>; Leanne Cochrane <leanne.cochrane@trilateralresearch.com>
Cc: Alessandra Calvi <Alessandra.Calvi@vub.be>
Subject: RE: Star II - publication for WP5
Hi Lina,
I’ll review it if you like. Can you send me the latest version?
DBW
From: Lina JASMONTAITE <Lina.Jasmontaite@vub.be>
Sent: 17 March 2020 17:08
To: Leanne Cochrane <leanne.cochrane@trilateralresearch.com>
Cc: David Barnard-Wills <David.Barnard-Wills@trilateralresearch.com>; Alessandra Calvi <Alessandra.Calvi@vub.be>
Subject: RE: Star II - publication for WP5
Dear Leanne,
I hope this email finds you well during these uneasy times.
I would like to ask you to review the paper in the upcoming week or two, so we can send it for a review to the EDPL.
I will be going on a maternity leave in mid-April and will not be available till late July. Of course, if we are asked to make some changes or implement comments of a reviewer, I will find time for
that.
In any case, even if the project is prolonged, it would be great to proceed with the publication as soon as possible as it takes some time.
Best regards,
Lina
From: Leanne Cochrane <leanne.cochrane@trilateralresearch.com>
Sent: Sunday, February 16, 2020 8:40 PM
To: Lina JASMONTAITE <Lina.Jasmontaite@vub.be>
Cc: David Barnard-Wills <david.barnard-wills@trilateralresearch.com>;
nagy.renata@naih.hu; Kulitsán Gábor <kulitsan.gabor@naih.hu>; 'STAR' <star@listserv.vub.ac.be>; Alessandra Calvi <Alessandra.Calvi@vub.be>;
Carlotta RIGOTTI <Carlotta.Rigotti@vub.be>
Subject: Re: Star II - publication for WP5
Dear Lina,
Many thanks for this and the previous email.
I am on leave until Tuesday 25th February. I will schedule time at that stage to take up the article again.
With best wishes,
Leanne
|
|
Leanne Cochrane Senior Research Analyst | Policy, Ethics and Emerging Technologies Team leanne.cochrane@trilateralresearch.com Mobile: +44 (0) 7545 955 242 Skype:@ljcochrane |
|
I send emails at a time that suits me. I don’t expect you to read, action or respond out of your own working hours. |
From: Lina JASMONTAITE <Lina.Jasmontaite@vub.be>
Sent: 10 February 2020 15:34
To: Leanne Cochrane <leanne.cochrane@trilateralresearch.com>
Cc: David Barnard-Wills <David.Barnard-Wills@trilateralresearch.com>;
nagy.renata@naih.hu <nagy.renata@naih.hu>; Kulitsán Gábor <kulitsan.gabor@naih.hu>; 'STAR' <star@listserv.vub.ac.be>;
Alessandra Calvi <Alessandra.Calvi@vub.be>; Carlotta RIGOTTI <Carlotta.Rigotti@vub.be>
Subject: Star II - publication for WP5
Dear Leanne,
Following up on the discussions last autumn, I prepared yet another draft of an article foreseen in task 5.2. It’s also saved on the shared folder with additional materials.
While I tried to keep it focused, I think some important issues remain untouched, such as that there’s a lot of guidance available by DPAs though it is not always clear how to find the relevant one; national guidance documents usually
build on the EDPB opinions or the EC, so guidance on EU level for SMEs should be encouraged. Now we suggested that such guidance should be primarily developed at national level. Throughout the contribution we mostly assume that there are distinctive needs
of SMEs but we never elaborate on them. Do you think we need to further elaborate on such needs? Perhaps, SME association expectations from DPAs should be also more nuanced?
@Kulitsán Gábor &
@Nagy Renáta perhaps you could provide some comments on this contribution?
Best regards,
Lina Jasmontaite
Doctoral researcher
Law, Science, Technology and Society (LSTS)
Vrije Universiteit Brussel (VUB)
Brussels Privacy Hub (BPH)
Room 4B306, Pleinlaan 2, 1050
Brussels, Belgium
https://lsts.research.vub.be |
www.brusselsprivacyhub.org
