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Data Protection Guidance - Question 15
Submission of the collected statements of support to Member States for verification – what are the roles and responsibilities when using the Commission file exchange service?
Applies under Case Scenario 2 when submission of statements of support is done via the Commission file exchange service
You may choose to ask the Commission to submit statements of support to Member States for verification even if these have been collected in paper form (under the sole data controllership of the representative).
What are the roles and responsibilities of the Commission?
- Makes available to the organisers the relevant IT system, pre-configured for the initiative.
- Makes available to them the encryption facility.
- Ensures secure and confidential submission to Member States of statements of support encrypted and uploaded by the organisers.
- Deletes the files stored in the submission facility once it has ensured with the group of organisers and Member States, that the submission has been completed.
- Transmits to the group of organisers data subjects’ requests for further handling.
- Provides a data protection impact assessment, a record of the processing activities and the services of its Data Protection Officer with regard to this processing operation.
What are the roles and responsibilities of the representative?
- Encrypts the statements of support (after scanning those collected in paper form)
- Uploads the encrypted statements of support in the file exchange service
- Decides on the date of submission to Member States’ competent authorities
- Handles under GDPR any data subject requests received at that stage of processing.
Full information as regards the obligations of both joint controllers is found in the relevant joint controllership agreements.
PLEASE NOTE:
You may also choose to submit statements of support collected using paper forms, using your own means.
References:
Articles 4(3), 10 and 12 of the Regulation on the European citizens' initiative
