DBA First iteration running phase

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[Work in progress]

Introduction

This page addresses general information about the first iteration running phase for the Doing Business Abroad pilot.

Estimated earliest start dates of pilot (use case 1)

	type	Data Evaluator	Data Owner	Companies	Status
May 2022	Simulation with real data	RO	NL	Dutch (real)	Pilot completed
	Real eProcedure with real data	NL	RO	Romanian (real)	Pilot completed
	Simulation with real data	SE	RO	Romanian (real)	Moved to 2nd iteration
	Simulation with real data	SE	NL	Dutch (real)	Moved to 2nd iteration
	Simulation with real data	SE	AT 1) 2)	Austrian (real)	Moved to 2nd iteration

1. Assuming that the Romanian/Dutch/Swedish eIDAS pilot node profile 1.1 can communicate with the AT eIDAS pilot node profile 1.2
2. The AT eProcedure will be connected to the AT eIDAS pilot node in July 2022

Legal risks and issues

Should any legal risks / issues apply to one or more of the combinations of DEs and DOs to be piloted, they will be mentioned here.

Measures taken

Measure description	Tick if this measure was taken	Description or comments (if any)
Piloting partners will communicate proactively towards each other on issues or incidents (always mandatory)	x	Will be done when issues arise, which is not yet the case.
Any real-life pilot participants (if applicable) are informed of the fact that they are involved in piloting activities, including any risks and countermeasures taken, and the (lack of) legal effects and consequences of participation. Appropriate documentation should be retained to demonstrate that this information has been provided. (mandatory for medium and high)	x
If the piloting involves real-life persons, piloting should be organised under the supervision of a DPO. (mandatory for medium and high)	x	Hans Graux
If the piloting would be done on a production environment, all pilot partners should notify any operators of such environments in advance. Appropriate measures should be taken that piloting activities do not result in negative legal or practical consequences for any real-life persons, real life data, or production environments. The production environments should be cleaned if the piloting activity was not intended to have long term legal or practical consequences. (mandatory for medium and high)	x	Operators and product owners are informed and attend pilot run sessions. The portal allows for registration only, but no subsidies or other services can be requested. Data on the companies will remain in DE systems, without any further legal or practical consequence, as no services can be requested.
All piloting activities should be monitored by pilot partners (each solely in relation to such components of the piloting activities which are under their responsibility) in a manner that allows any incidents to be detected and remedied (including by contacting any affected real-life persons where needed). (mandatory for medium and high)	x	Piloting activities are monitored by pilot partners.
The DE4A project DPO (Hans Graux) should be informed prior to initiating piloting activity, and of any incidents that are reasonably likely to create legal effects or practical impacts on any real-life persons (mandatory for high)	x	This wiki informs the DPO.
Implementation of a pilot monitoring and remediation strategy to assess whether exchanged evidences are reasonably capable of satisfying the requirements for high risk piloting documented in the deliverables, and to ensure that any errors in the piloting activity can be detected and remediated in a manner that eliminates any negative legal or practical consequences. (mandatory for high)	x	[Pilotruns are attended by DBA partners, to identify any errors and eliminate consequences. Recordings of pilotruns will be captured as project-evidence, although all personal and company-date will be blurred before storing this evidence.

End date of the pilot running phase

The first iteration running phase ended July 2022.