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Monday 01 July 2013

EPA Letter to the Editor of the Financial Times

Dear Mr. Editor,

I am writing in my quality of Scientific Director of the European Privacy Association (EPA) referring to the article entitled Brussels: Astroturfing takes root by James Fontanella-Khan published online yesterday in the Financial Times. 

The article offensively defined EPA as an example of an "astroturfing" organization, used tendentious phrases such as "the group was forced to come clean" and reported inaccurate and biased information including "quietly changed its status in the register from think-tank to in-house lobbying group".

As the rest of the distinguished members of our Policy and Scientific Committee, I am surprised to see an article that clearly concerns our Association while none of us have been contacted or have been in contact with the reporter.  We would have been able to provide some very useful information about who we are and the scientific research that we conduct which is currently being published in leading international law journals.  Additionally, according to our records, the reporter has never attended one of our official events. 

Before providing you with a short description of our Association I would like to stress that we are not a privacy advocacy or consumer group.  We are not in Brussels to ideologically define privacy.  Instead, we created EPA to enhance the debate around privacy, data protection, data and data security and in fact, since the birth of our organization we have followed an approach aimed at balancing individual rights regarding data and those of the companies and governments that use data to empower economic growth and innovation.  We believe that through consistent balance the debate can be enhanced and that both companies and individuals can live in an increasingly prosperous and free world. 

We are also very surprised by the fact that a small organization like EPA is able to attract  so much attention.  We understand that this goes beyond our merit. We are, in fact, at the center of a harsh debate fueled by various clashing interests.  This is likely because, to the best of our knowledge, there are no other organizations in Brussels or other major European capitals that do the same work we do.  Maybe we were too naïve to expect congratulations for our work, which I would like to stress, is conducted on a primarily voluntary basis, regardless of how it could be evaluated.   We would have genuinely appreciated any type of criticism or challenge regarding our work or the positions that we take on the basis of scientific analysis, instead of simply being assailed because of who our Supporters are. 

EPA is a pan-European think-tank based in Brussels that brings together data protection/security experts and businesses to engage in developing new policies that enhance data protection and data security while assuring sustainability for the development of current and new business and helping data subjects successfully manage their data. Since the foundation of EPA the Association has attempted to achieve an open dialogue with stakeholders, industry, NGOs, policy makers, and other parties that add to the debate. EPA’s work is accessible to all and is successful precisely due to the fact that EPA engages in open debates, welcoming confrontation from all interested parties.  EPA follows a liberal approach that accurately balances the fundamental rights of citizens with the prosperous and innovative market.

EPA conducts its activities - which mainly consist of managing the website, the Daily Privacy Newsletter, carrying out research, writing papers and presenting research results at international conferences, EPA Privacy Breakfast/Lunches and dedicated national and international events to which it is regularly invited - thanks to the sponsorship of its Supporters. Any Supporter of EPA is strongly encouraged to provide input regarding EPA's activities and share their best practices with EPA. No EPA Supporter may, however, make impositions regarding content, methodology or research output.

Recently EPA had to change its status from "Think-tank" to the specific sub-category of  "Trade, business & professional associations" and not “In-house lobbying group” - the difference is not trivial.  We made this change because the Transparency Register Compliance Guidelines do not allow think-tanks to have corporate members or supporters, "As soon as there is a profit-making element in its membership (at whatever sublevel), the entity must register in one of the subcategories foreseen under section II, i.e., "In-house lobbyists and trade/professional associations".

Moreover, the Fellows and Members of the Policy & Scientific Committee are all highly respected data protection and data security professionals. Thanks to their incredibly valuable support all of EPA’s recent research papers have been accepted for publication in top International law reviews. 

It is rather unfortunate that the journalist did not contact us before defining us as an example of  "astroturfing", we would have certainly provided him with some useful information that could have eventually helped improve the credibility of the article and avoid offending the distinguished professionals that I represent as the Scientific Director of the European Privacy Association. 

Therefore, exercising the right of rectification, I hereby kindly request you to publish this letter in order to clarify the matter and reply to the allegations made against EPA.

I thank you in advance for your cooperation.

Best regards,

Paolo Balboni


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