The Federal Data Protection Commissioner of Germany, Ulrich Kelber, issued a statement voicing his concerns about the most problematic element of the bill in its current form: upload filters.
Even though upload filters are not explicitly mandated by the bill, they will be employed as a practical effect. Smaller service providers wouldn’t be able to develop such filters themselves, therefore they will utilize offerings by large IT companies.
“At the end of the day, this would result in an oligopoly consisting of a few vendors of filtering technologies, which would then be instrumental to more or less the entire Internet data traffic of relevant platforms and services. The wealth of information those vendors would receive about all users in the process is evidenced by, among other examples, current media coverage of data transfers by eHealth apps to Facebook.”