Metadata collection

Call for Evidence on Metadata Retention for Criminal Proceedings

EU-commission Reference: Ares(2025)4081079

On May 21, the EU Commission invited Open Knowledge Sweden to respond to the Call for
Evidence on Metadata Retention for Criminal Proceedings.

Open Knowledge Sweden provides the following comments:

– The security ramifications of breaking end-to-end encryption of number-independent
services are incalculable.
Open Knowledge Sweden believes that end-to-end encryption should never be broken.

– The Internet’s architecture explicitly allows solutions on top to be separated from the
network
itself.
Just as the network’s content is separate from the Internet itself, the content of
end-to-end encrypted messages is separate from the provision of the communications
service.

– The metadata retention requirements are too far-reaching.
Metadata retention should always be kept at an absolute minimum.

‘Open knowledge’ is any content, information or data that people are free to use, re-use and
redistribute — without any legal, technological or social restriction. The proposal “Metadata
retention for criminal proceedings” is not open knowledge, should not be open knowledge –
nor is it compatible with EU legislation nor democracies in the EU.

The Internet is for everyone.

Mattias Axell
Chairman
Open Knowledge Sweden

https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14680-Impact-assessment-on-retention-of-data-by-service-providers-for-criminal-proceedings-/F3567126_sv