Lessons from IP Markets for Data Markets: On
Moral Rights, Property Rules, and Resale
Royalties
Dr Philipp Hacker
*
Comparative law; Compensation; EU law; Intellectual property;; Personal data; Resale right; United
States
Abstract
IP law offers manifold insights to the current debate on the optimal regulatory environment for markets
in personal data. This article contributes to this transdisciplinary debate by making three novel
interventions. First, it shows that IP rights and personal data are comparable not only with respect to
their theoretical foundations, but also in light of recent empirical studies from the US and the EU about
user attitudes and valuations of the respective rights. On this basis, secondly, the article explores how far
the interlinked system of property, liability and inalienability rules in existing IP law offers a blueprint
for the contested regulation of markets in personal data. In both fields, the interests of control, access
and adequate compensation have to be balanced. In the digital economy, control is increasingly illusory;
therefore, the question of adequate compensation to users for data they share becomes ever more relevant.
Hence, thirdly, the article proposes transplanting the artists’ resale right from copyright law to guarantee
users a fair share in the value of their personal data as it unfolds over time. Overall, the article shows
that a careful analysis of the similarities, and differences, between IP rights and personal data can make
a meaningful contribution to the pressing question of control, access and compensation in the digital
economy.
Introduction
In January 2017, the European Commission published a Communication entitled “Building a European
Data Economy”.
1
In it, the Commission proposes a principle of free movement of data within the EU in
order to advance the fundamental freedoms enshrined in the EU treaties.
2
Furthermore, it hints at a “data
producers’ right” that could govern the use of non-personal data
3
; the Commission intends to subject
personal data, by contrast, to the current “notice and consent” regime epitomised by the General Data
Protection Regulation (GDPR).
4
Generally, the Commission aims to create a comprehensive framework
for data access, trade and ownership that leads to a “fair sharing of benefits between data holders, processors
and application providers”.
5
Shortly after the Communication, in March 2017, the Republican-led US
House of Representatives voted to repeal privacy protection for personal data processed by internet
providers, removing consent requirements and effectively handing over user data to cable companies and
*
A.SK Fellow, WZB Berlin Social Science Center; Research Fellow, Centre for Law, Economics and Society, and Centre for Blockchain Technologies,
both UCL.
1
Commission, “Building a European Data Economy”, COM(2017) 9 final.
2
Commission, “Building a European Data Economy”, COM(2017) 9 final, pp.5–6.
3
Commission, “Building a European Data Economy”, COM(2017) 9 final, p.13.
4
Commission, “Building a European Data Economy”, COM(2017) 9 final, p.13.
5
Commission, “Building a European Data Economy”, COM(2017) 9 final, p.11 (emphasis added).
45 [2018] I.P.Q., Issue 1 © 2018 Thomson Reuters and Contributors