Insurance EuropeInsurance Europe
Position Paper
Contribution to the second Council of Europe consultation on the modernisation of Convention 108

Insurance Europe, the European insurance and reinsurance federation, welcomes the opportunity to contribute to this second consultation on the modernisation of Convention 108, launched by the Council of Europe.

Insurance Europe participated in the first Council of Europe consultation in 2011 and is content to see that some of its concerns raised previously have been taken into consideration by the T-PD committee. This being said, Insurance Europe would like to comment on the following points of the new proposals on the modernisation of the Convention 108.

Insurance Europe notes that European Commission Directive 95/45 on data protection is currently under revision and hopes there will be no significant discrepancies between the future modernised Council of Europe Convention 108 and the future EU Regulation and Directive.

Published 2 April 2012