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Data Protection Guidance - Question 18
Support and funding – what should you be aware of when processing personal data?
As a group of organisers, you must indicate, for the European citizens’ initiative public register and where appropriate on your campaign website, clear, accurate and comprehensive information on the sources of support and funding for your initiative.
Information to be provided on support and funding:
- The support and funding received from any source that exceeds EUR 500 per sponsor (this covers both financial support and support in kind)
- The organisations assisting it on a voluntary basis, where such support is not economically quantifiable.
Therefore, you need to collect personal data of natural persons who supported initiatives with amounts exceeding EUR 500, and namely:
- full name of sponsor
- date of donation
- amount of donation (exceeding EUR 500).
Timeline to provide information on support and sponsors:
This information needs to be provided in particular at the time of registration of a proposed initiative and at the time of its submission to the European Commission (when the required 1 million signatures have been certified), but should also be updated every two months. You should communicate these data to the European Commission via a dedicated form in your organiser account in view of its publication in the public register.
Rules and roles related to data protection:
As regards these data, the representative of the group of organisers is a sole data controller, and the European Commission plays the role of data processor while publishing this information in the register.
The processing of personal data of sponsors being natural persons is subject to the requirements of the GDPR similar to those applicable to the signatories’ data.
If they are natural persons, sponsors must be provided with an appropriate privacy statement by the group of organisers at the time their data are collected. They should in particular be made aware by the organisers that their data will be published in the register.
Under the Regulation on the European citizens’ initiative, sponsors are entitled to object to the publication of their personal data on compelling legitimate grounds relating to their particular situation, and to request the rectification of that data at any time.
References:
- Article 17 and Annexes II and VII of the Regulation on the European citizens' initiative
