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CSC supports the vision presented in the assessment but emphasises that it will lead to a significant change that requires a comprehensive legal assessment and appropriate change leadership and resourcing. The need for new legislation must be assessed both for the digital identity itself and the market of the digital wallets for storing the digital identities. The suggested solution must also be in line with existing legislation which may prove difficult especially in case of data protection regulation.

In CSC’s view the idea of separating the digital identity and the tool for using it is functional but it must be kept in mind that the resulting market of digital wallets requires cooperation between the public and the private sector as well as clear division of responsibilities between them. It is also important to ensure interoperability between the solutions developed by different actors.

CSC notes that while the suggested solution increases individuals’ control of their personal data it also increases their responsibility of sharing their data and may even lead to additional costs for them as they become the only de facto customer of the market of digital identification. These viewpoints must be taken into account when planning the reform and communicating about it.

Read the full statement (pdf) (in Finnish)