Data governance at the crossroad of privacy, competition, and national security

Oscar Borgogno (Bank of Italy)
Michele Savini Zangrandi (Bank of Italy)


Systematic data exploitation through digital means lays at the very heart of the current platform economy. The regulatory boundaries posed by legislation to what firms and individuals can do with this intangible asset fall under the broad concept of data governance. We argue that the three major regulatory policy fields critical in shaping a country’s data governance framework are data control, national security and competition law. These legislative strands have a profound impact on the platform economy and overlap with each other in a significant manner. In exploring the complex trade-offs, this paper reaches three broad conclusions. First, multiple and diverse regulatory domains intersect the digital space, with overlapping and sometimes unpredictable consequences. Second, given the transnational nature of digital activity, international coordination and dialogue are of the utmost importance. Third, as the data governance framework has important consequences for the financial sector, sectoral regulators should be open to taking an active part in national and international discussions.

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