Request for Comments: CIOs and cloud providers invited to provide feedback on new draft Code of Conduct for switching cloud infrastructure providers and avoiding vendor lock-in

Jun 12, 2018 | News

Brussels, 12/06/2018 – Anticipating the European Commission’s regulation for the Free Flow of non- personal Data, the SWIPO IAAS (Infrastructure as a Service) Working Group has today launched a Request for Comments for cloud users and providers to help inform and shape its proposed draft Code of Conduct.

To help support the effective application of the Free Flow of non-personal Data in Europe, cloud users and leaders in the cloud infrastructure sector have collaborated to draft a new draft Code of Conduct, which defines rules, approaches and requirements for service providers to agree and follow.

“It’s important for responsible cloud providers to anticipate the regulation, hence this request for comments on the first draft of a Code of Conduct,” says Alban Schmutz, co-chair of the SWIPO (Switching and Porting) IAAS Working Group, chairman of CISPE and VP Strategic Development & Public Affairs, OVH. “Avoiding vendor lock-in is critical to enable steady growth of the cloud market and deliver the best services for customers.”

“Our members are using more and more cloud infrastructure services,” adds Freddy Van den Wyngaert, co-chair of the SWIPO IAAS Working Group and General Secretary of EuroCIO and. “Having clear rules that will help us to select providers as well as accelerating the free flow of data in Europe is key.”

  • The draft Code of Conduct and the Questionnaire issued for Request for Comments are available here:
  • Deadline for feedback: 2 July 2018 – 11:00 CET

The first results of the Request for Comments will be presented in Paris on July 4th – the first meeting of the European Commission’s Digital Single Market Cloud Stakeholder group outside Brussels.

Regulatory Context

Article 6 of the Free Flow of non-personal Data Regulation, proposed by the European Commission on September 13th 2017 and agreed by Member States in December 2017, asks for a self-regulatory process. It expects the industry to take the lead in developing Code of Conduct to implement the regulation. To address this issue, the SWIPO (Switching & Porting) Working Group was established under the umbrella of the Cloud Digital Single Market Working Group of the European Commission (EC DSM Cloud Stakeholder Group). From April 17th 2018, sub-groups for Infrastructure as a Service (IaaS) and Software as a Service(SaaS) started developing a Code of Conduct in anticipation of the coming regulation.

SWIPO IAAS Working Group

Representing the interests of cloud providers and users alike, SWIPO IAAS co-chairs are Alban Schmutz (CISPE, OVH) and Freddy Van den Wyngaert (EuroCIO). The Code of Conduct, published today for feedback, was created by the Core Drafting Group to represent a balanced number of users/providers, geographical spread, different sizes of company (e.g. SME, Small Caps, corporations) and a variety of sectors (e.g. legal, production, architecture). Members of the Core Drafting Group: CISPE/OVH (co-chair), EuroCIO (co-chair), Aruba, AWS, CERN, CIO Platform, Credit Suisse, IBM, Prologue, Santander, UpCloud. Other IaaS experts from various organisations are represented in the SWIPO IAAS Working Group.

Adoption of the Code and Process

Once the Request for Comments is complete, the SWIPO IAAS Core Drafting Group will present results to the entire SWIPO IAAS Working Group on July 4th in Paris and discuss further issues to be integrated into the text. Added value input from stakeholders, experts and the request for comments will enable the code to be updated after this meeting. SWIPO IAAS expert groups may then adopt the code at a simple majority if there is not opposition of one-third of users’ representatives or one-third of providers’ representatives.


Alban Schmutz +33 6 52 45 74 92

Freddy Van den Wyngaert