European Magazine Media Association

Press publishers’ feedback on the Roadmap1 on the Report on the application of the General Data Protection Regulation (GDPR) Brussels, 28 April 2020 To the attention of DG JUST Units C3 and C4 We write to you on behalf of the EMMA (the European Magazine Publishers’ Association) and ENPA (the European Newspaper Publishers’ Association) which together represent the vast majority of European news and media companies, with an outreach to almost the entirety of the European market. EMMA and ENPA’s mission is to ensure that the freedom of the press is and continues to be a core European democratic value. A balanced and coherent regulatory environment on national and European level is therefore necessary. The GDPR touches upon several vital preconditions for the financing and distribution of the free press in print and online, e.g.

…touches upon several vital preconditions for the financing and distribution of the free press in print and online, e.g. the processing for journalistic purposes, direct marketing and subscription acquisitions. It is therefore of utmost importance of finding a balanced and practical application of all legal grounds for processing enshrined in the GDPR. All Member States must implement such an element coherently in order to provide both high level of data protection while ensuring competitive environments for all business models and protecting media pluralism and press freedom in Europe. Hence, the provisions enshrined in the GDPR create a fine, at times even delicate balance for the sustainability of the press’ business models.

…in the GDPR create a fine, at times even delicate balance for the sustainability of the press’ business models. This is why EMMA and ENPA strongly believe that the input of European press publishers’ could provide the European Commission with a unique outlook in terms of the impact the GDPR on the European press sector both in terms of sustainability and media freedom. The Roadmap announces that the report will consider the contributions from the Council, the European Parliament, the European Data Protection Board and those received from the GDPR Multi- Stakeholder Group (business and civil society representatives). Additionally, the roadmap highlights that the problems the initiative aims to tackle are in particular the international transfer of data as well as the cooperation and consistency mechanisms between national DPAs.

…the international transfer of data as well as the cooperation and consistency mechanisms between national DPAs. We therefore take note that the Roadmap does not foresee a public consultation which would be opened to all stakeholders and that it will be limited in scope. This would represent a missed opportunity, as the report’s stated objective is to identify possible issues in the application of the GDPR. We strongly believe that the European press sector could help identify such issues, that would be common for a majority of press publishers across the EU. As such, the upcoming European Commission’s report is of great relevance to our members and we would be grateful for the opportunity to provide feedback on the application of the GDPR. We would therefore like to enquire whether the European Commission will consider feedback on issues with the application of the GDPR at a later stage.

…whether the European Commission will consider feedback on issues with the application of the GDPR at a later stage. Such an opportunity, in full alignment with the principles of better regulation, would therefore be greatly welcome. Yours sincerely, Ilias Konteas EMMA-ENPA Executive Director [email protected] / [email protected] 1 https://ec.europa.eu/info/priorities/justice-and-fundamental-rights/data-protection/2018-reform-eu-data- protection-rules/eu-data-protection-rules_en Ref. Ares(2020)2263975 - 28/04/2020 EMMA, the European Magazine Media Association, is the unique and complete representation of Europe’s magazine media, which is today enjoyed by millions of consumers on various platforms, encompassing both paper and digital formats. EMMA represents 15,000 publishing houses, publishing 50,000 magazine titles across Europe in print and digital.

EMMA represents 15,000 publishing houses, publishing 50,000 magazine titles across Europe in print and digital. See: www.magazinemedia.eu/ ENPA, the European Newspaper Publishers’ Association (ENPA) is the largest representative body of newspaper publishers across Europe. ENPA advocates for 16 national associations across 13 European countries, and is a principal interlocutor to the EU institutions and a key driver of media policy debates in the European Union. See: www.enpa.eu/

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