Code of Conduct for Cloud Computing: Question to the European Commission

Update January 2015: The written answer is now available on the European Parliament website at: http://www.europarl.europa.eu/sides/getAllAnswers.do?reference=E-2014-008722&language=EN.

At the meeting of the DPA's Digital Single Market Group on 13th October, it was noted that the proposed Code of Conduct for Cloud Computing (CoC) raised a number of concerns, particularly for SMEs.  Furthermore, it is likely that many cloud computing service providers are unfamiliar with developments and what the implications of the proposals would be.  There is therefore a need to raise awareness, particularly as the CoC is being presented as a voluntary code for cloud providers, notwithstanding multiple references to the CoC in the General Data Protection Regulation, which may therefore render the code effectively mandatory for cloud providers in the EU.

It was agreed that the Group would propose a question for Vicky Ford MEP, chair of the Internal Market Committee (IMCO) to ask in the EU Parliament on the Code of Conduct for Cloud Computing. The question can be multi-part, and the European Commission is obliged to answer it. After consulting with interested members of the DPA to ensure that we reflect consensus, the suggested question on the Code of Conduct for Cloud Computing is as follows:

Given that the drafting team of the Cloud "Select Industry Group" (C-SIG) Code of Conduct Subgroup has no SME Cloud Service Provider representation, does the Commission have any plans to consult SME Cloud Service Providers on the provisions of the Code of Conduct for Cloud Computing, and on common guidelines for service level agreements, in order that SME Cloud Service Providers are made aware of the proposed guidelines, and have an opportunity to engage in advance of the implementation of the guidelines?

How many representations on the Code of Conduct for Cloud Computing from SMEs have been received by the C-SIG Working Group? What efforts are the Working Group making to ensure that SME's concerns are addressed when drafting the CoC?