Data intermediation services | Traficom
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Transport and Communications Agency

Data intermediation services

Data intermediation services function as neutral third parties that connect data owners willing to share data with data users. Data intermediation services enable the transmission of data between different actors and applications based on agreements. As of the start of 2024, companies providing data intermediation services are required to submit notifications of their activities to Traficom.

Data intermediation services include: 

  • data marketplaces 
  • orchestrators of data sharing ecosystems, for instance in the context of common European data spaces
  • services aimed at data subjects. Such data intermediation services seek to enhance the agency of data subjects, and in particular individuals’ control over data relating to them, which is stored in personal data filing systems, such as customer databases.
  • data cooperatives, which can seek to strengthen the position of individuals in making informed choices before consenting to data use, for example. Data cooperatives are organisations consisting of data subjects, one-person undertakings or SMEs.

More precise definitions are provided in the DGA.

Data intermediation services are subject to the following requirements, among others:

  • Data intermediation services cannot use the data that they intermediate for purposes other than to put them at the disposal of data users.
  • A data intermediation service must operate through a separate legal person.
  • The commercial terms of a data intermediation service, such as pricing, cannot depend on whether the data holder or data user uses other services provided by the same service provider or by a related entity.
  • The data collected with respect to any activity of a natural or legal person for the purpose of the provision of the data intermediation service can be used only for the development of that data intermediation service.
  • The data intermediation services provider must facilitate the exchange of the data in the format in which it receives it from a data subject or a data holder. The data can be converted into specific formats only to enhance interoperability.
  • Access to data intermediation services must be fair, transparent and non-discriminatory.

Detailed conditions for providing data intermediation services:

Article 12 of the Data Governance Act

Data intermediation services are required to submit notifications to Traficom

As of the start of 2024, Traficom will start accepting notifications from data intermediation services.
Service providers can request confirmation of their submission of the notification when submitting it. Traficom will provide the confirmation in the form of a separate email message within one week of the submission of the notification.

You can also ask Traficom to confirm whether the company for which you submitted the notification meets the requirements set for data intermediation services. Companies that receive confirmation of this from Traficom may use the label ‘recognised data intermediation service’ and a common logo.

Submit notification for data intermediation services

Traficom will relay the information provided in notifications to the European Commission, which maintains a register of all data intermediation services providers. For more information on the information stored in the register and disclosed to the Commission, please see the privacy statement.
 

Privacy statement: data intermediation services (pdf, 121 kt)
EU register of data intermediation services
Commission instructions for the use of logos

Data intermediation services must also submit notifications of changes

If the information notified to Traficom changes, the data intermediation services provider must notify Traficom of the changes within 14 days. If a data intermediation services provider discontinues its activities, it must notify Traficom of this within 15 days. Notifications of changes are submitted via email to kirjaamo@traficom.fi. 

Regulation (EU) 2022/868 of the European Parliament and of the Council on European data governance and amending Regulation (EU) 2018/1724 (Data Governance Act)

(EU) 2022/868Valid from: 30/05/2022

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