Gerard de Graaf, First Secretary of the Delegation of the European Commission here in Washington, began his commentary by stressing that the dialogue is ongoing and, that from the Commission's viewpoint, quality is more important than speed. He noted that data privacy is of fundamental importance, not only a commercial issue. While progress has been made on many fronts since the last summit, De Graaf asserted that from the EU's perspective, there remain many outstanding issues. Furthermore, the list of participants should be as firm as possible. The EU is also concerned about how to deal with noncompliance or withdrawal.
Enforcement is another key issue.
Self-regulation must have enforcement teeth in order to get the job done. How damages will be provided under US legislation must also be made more explicit. The inclusion of US Financial Modernization Act compliance in the document is a detour in the eyes of the EU, as it would only delay the process of self-certification. De Graaf also challenged the notion that it is impossible to legislate in the face of the rapid pace of technological change. When the ministers reviewed the Ottawa guidelines set in the mid-1980s, they saw no need for modification.