As an OEM and Data Holder under the EU Data Act, you have to fulfil two main obligations with technical implications:
raw data sharing with users
raw data sharing with third parties
You have a right too, and it would be a shame not to exploit it:
get a reasonable compensation from third parties
Implementing raw data sharing with users
This is what the law prescribes:
where data cannot be directly accessed by the user from the connected product the data holder shall make available raw data to the user
raw data data shall be made available:
without undue delay, easily, securely
of the same quality as is available to the data holder
free of charge
in a comprehensive, structured, commonly used and machine-readable format
where relevant and technically feasible, continuously and in real-time
the obligation includes also the relevant metadata necessary to interpret and use those data
So here is the minimum set of capabilities you need:
manage users’ requests to access raw data
enable them to access raw data in the way, the granularity, the frequency (eg in real-time) that is already possible for you.
Implementing raw data sharing with third parties
This is what the law prescribes:
upon request by a user (or by a party acting on behalf of a user) the data holder shall make available raw data to a third party
raw data shall be made available:
without undue delay, easily, securely
of the same quality as is available to the data holder
free of charge to the user
in a comprehensive, structured, commonly used and machine-readable format
where relevant and technically feasible, continuously and in real-time
the obligation includes also the relevant metadata necessary to interpret and use those data.
These obligations also apply if the user has direct access to raw data.
So here is the minimum set of capabilities you need:
manage third party entities
manage users’ requests to share raw data with a third party
manage authorizations
enable an authorized third party to access raw data in the way, the granularity, the frequency (eg in real-time) that is already possible for you.
Implementing compensation collection
In order to collect the compensation you are entitled to from third parties, you need this minimum set of capabilities:
manage compensation policies
manage compensation calculation
manage billing to third parties
manage payment collection