The Commission\u2019s Recommendation dates back to 2011, which is why it is less competent to deal with the issues of rapidly developing technologies in respect to the cultural heritage preservation with each passing year. This point was raised, in its response, by Communia as well.<\/p>\n
Communia\u2019s response emphasizes the need for a broad definition of cultural heritage which would encompass its modern forms as well, the need for development of public infrastructure that would ensure access to and use of cultural heritage, and the need for not just preservation but access and usage of cultural heritage works as well. Additionally, Communia pointed towards the importance of an appropriate implementation of the new DSM Directive<\/a>, and suggested that the Directive 2012\/28 on certain permitted uses of orphan works<\/a>\u00a0be retracted, considering that even after 5 years after its entry into force, it has not had any meaningful impact on the European cultural heritage digitisation.<\/p>\n