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

Insurance Europe participated in the second Council of Europe consultation this year and would like to comment on the following points of the new proposals on the modernisation of the Convention 108 (27 April 2012) which were already addressed during the meeting between the Council of Europe and the private sector stakeholders on 2 May 2012.

Having in mind the on-going process of revision of the European Commission Directive 95/45 on data protection, Insurance Europe wishes to reiterate its expectation that there will be no significant discrepancies between the future modernised Council of Europe Convention 108 and the future EU Regulation and Directive.