Processing operation: ECI Communication Campaign
Data Controller: European Commission, Secretariat-General, Unit SG.A.1 ‘Policy Priorities & Work Programme’
Record reference: DPR-EC-09286
1. Introduction
The European Commission is committed to protect your personal data and to respect your privacy. The Commission collects and further processes personal data pursuant to Regulation (EU) 2018/1725 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data by the Union institutions, bodies, offices and agencies and on the free movement of such data.
This privacy statement explains the reason for the processing of your personal data, the way we collect, handle and ensure protection of all personal data provided, how that information is used and what rights you have in relation to your personal data. It also specifies the contact details of the responsible Data Controller with whom you may exercise your rights, the Data Protection Officer and the European Data Protection Supervisor.
The information in relation to processing operation ‘ECI Communication Campaign’ undertaken by Unit A.1 of the European Commission Secretariat-General (Unit SG.A.1), is presented below.
2. Why and how do we process your personal data?
The ‘ECI Communication Campaign’ is carried out by the European Commission in accordance with Article 18(1) of Regulation (EU)2019/788 of the European Parliament and of the Council of 17 April 2019 on the European citizens' initiative. Its objective is to ‘raise public awareness about the existence, objectives and functioning of the European citizens' initiative through communication activities and information campaigns, thereby contributing to promoting the active participation of citizens in the political life of the Union.’
The aim of the collection and processing of your contact details as ECI stakeholders or other interested citizens (including minors) by Unit SG.A.1, is to allow you to be invited to participate in any further activities of the ECI Communication Campaign, such as targeted consultations, video competitions or other participatory activities, participation in events as speakers, featuring in promotional materials and audiovisual content, etc. For this purpose, Unit SG.A.1 processes the contact details of the relevant ECI stakeholders and interested citizens.
In most cases, your contact details are processed, following to or as part of an earlier processing in the context of one of the other processing operations relevant in the context of the ECI Communication Campaign in particular:
- If you are an ECI organiser or an official from the national authorities involved in the implementation of the ECI Regulation – your data are processed in the context of the Commission data processing record DPR-EC-00068,
- If you are an ECI ambassador or you have provided an individual testimonial on your ECI experience or audiovisual content in the context of video competitions or other participatory activities – your data are processed in the context of the Commission data processing record DPR-EC-09286 and the privacy statement of the specific participatory activity concerned,
- If you have participated in an ECI communication event as a speaker - your data are processed in the context of the Commission data processing record DPR-EC-01063 and the privacy statements of the specific event concerned,
- If you have participated in a targeted consultation in the context of the ECI - your data are processed in the context of the Commission data processing record DPR-EC-01011 and the privacy statements of the specific consultation concerned,
- If you have proactively entered in contact with the Commission on a subject related to the ECI – your data are processed in the context of the Commission data processing record DPR-EC-01386.
Any such processing for the above-mentioned purposes is always subject to a relevant specific privacy statement and, where applicable, to your specific consent.
It is also possible that you have been identified by SG.A.1 or its contractors as a potential ECI stakeholder based on the information, which has been sourced from relevant official or Commission databases, existing local Commission or agency relationships and publicly available sources.
Your personal data will not be used for an automated decision-making including profiling.
3. On what legal ground(s) do we process your personal data?
According to Article 18(1) of the ECI Regulation, ‘The Commission shall raise public awareness about the existence, objectives and functioning of the European citizens' initiative through communication activities and information campaigns, thereby contributing to promoting the active participation of citizens in the political life of the Union.’
In this context, the collection and processing of the contact details of relevant and interested ECI stakeholders is based on Article 5(1)(a) of Regulation (EU) 2018/1725, because it is considered to be necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Union institution or body.
However, certain processing relevant in the context of the ECI Communication Campaign may require a specific consent of the data subject concerned in accordance with Article 5(1)(d) of Regulation (EU) 2018/1725, such as the collection of individual testimonials, audiovisual content and the creation of the ECI promotional and training materials featuring such testimonials or content and the involvement of ECI ambassadors to help promote the ECI values and messages on the ground in the EU Member States or at EU level.
4. Which personal data do we collect and further process?
In order to invite you to participate in an ECI communication event, video competition or other participatory activity, or in a targeted consultation survey as ECI stakeholder, we can process the following data: contact details as received from you, or sourced from relevant official or Commission databases, existing local Commission or agency relationships and publicly available sources, in particular first name, last name, job/function title, organisation/initiative name (if you are an ECI organiser), interests, nationality/language preferences, phone number, e-mail address, voice and image recorded in audio and video formats and photographs/visuals.
If you consent to collaborate as ECI ambassador, we will process in addition to the data listed above: assessments of the Commission and of the contractors leading to your selection as ECI ambassador, ECI ambassador charter signed, short bio notes and photos published on the ECI website, views and opinions being part of your exchanges with the Commission and the contractors, your social media account usernames, reports from the social media and other promotional activities established by the contractor based on the publicly available information or information provided by you directly.
If you consent to provide an individual testimonial on your ECI experience as part of the ECI Communication Campaign we will also process short bio notes, voice and image recorded in audio and video formats and photographs/visuals, age, gender, interests, nationality/language preferences, phone number, e-mail address, social media account usernames; views and opinions being part of your exchanges with the Commission and the contractors.
5. How long do we keep your personal data?
Unit SG.A.1 keeps your contact details for the time necessary to fulfil the purpose of collection or further processing, namely for a maximum period of 5 years from the collection or from the last contact you have initiated with the Commission in the context of the ECI, whichever comes later. However data will be deleted earlier in case you inform us that you will not be a relevant ECI contact anymore (for instance in case of change of jobs).
Recordings of the individual testimonials as collected are kept for a maximum period of 3 years from the date of collection. Documents (reports, correspondence, financial information, etc.) containing personal data, collected or produced in the context of recording of the individual testimonials are kept for a period of 10 years. Published promotional, audiovisual and training content is kept on the long term.
Note that other retention periods apply for the processing of your personal data in the context of other processing operations contributing to the ECI Communication Campaign in accordance with the relevant privacy statements.
6. How do we protect and safeguard your personal data?
All personal data in electronic format (e-mails, documents, databases, uploaded batches of data, audiovisual content, etc.) are stored either on the servers of the European Commission or of its contractors. All processing operations are carried out pursuant to Commission Decision (EU, Euratom) 2017/46 of 10 January 2017 on the security of communication and information systems in the European Commission.
The Commission’s contractors are bound by a specific contractual clause for any processing operations of your data on behalf of the Commission, and by the confidentiality obligations deriving from the General Data Protection Regulation ('GDPR' Regulation EU(2016/679 and relevant national implementing measures in the EU Member States. The host servers on which Netcompany – Intrasoft S.A processes and stores its databases are located exclusively within the European Union.
In order to protect your personal data, the Commission has put in place a number of technical and organisational measures. Technical measures include appropriate actions to address online security, risk of data loss, alteration of data or unauthorised access, taking into consideration the risk presented by the processing and the nature of the personal data being processed. Organisational measures include restricting access to the personal data solely to authorised persons with a legitimate need to know for the purposes of this processing operation.
7. Who has access to your personal data and to whom is it disclosed?
Access to your personal data is provided to the Commission staff responsible for carrying out this processing operation, to authorised staff according to the ‘need to know’ principle, and to contractor’s (Netcompany – Intrasoft S.A) authorised staff. Such staff abide by statutory, and when required, additional confidentiality agreements.
We may share your publicly available contact details with the other ECI stakeholders.
8. What are your rights and how can you exercise them?
You have specific rights as a ‘data subject’ under Chapter III (Articles 14-25) of Regulation (EU) 2018/1725, in particular the right to access, rectify and where applicable, the right to erase your personal data, the right to data portability and the right to restrict the processing of your personal data.
You have the right to object to the processing of your personal data, which is lawfully carried out pursuant to Article 5(1)(a).
Insofar you have consented to the processing of your personal data to the Data Controller for the present processing operation, you can withdraw your consent at any time by notifying the Data Controller. The withdrawal will not affect the lawfulness of the processing carried out before you have withdrawn the consent.
You can exercise your rights by contacting the Data Controller, or in case of conflict the Data Protection Officer. If necessary, you can also address the European Data Protection Supervisor. Their contact information is given under Heading 9 below.
Where you wish to exercise your rights in the context of one or several specific processing operations, please provide their description (i.e. their Record reference(s) as specified under Heading 10 below) in your request.
9. Contact information
- The Data Controller
If you would like to exercise your rights under Regulation (EU) 2018/1725, or if you have comments, questions or concerns, or if you would like to submit a complaint regarding the collection and use of your personal data, please feel free to contact the Data Controller, European Commission, Unit SG.A.1 ‘Policy Priorities & Work Programme’: SG-ECI-mailing@ec.europa.eu
- The Data Protection Officer (DPO) of the Commission
You may contact the Data Protection Officer (DATA-PROTECTION-OFFICER@ec.europa.eu) regarding issues related to the processing of your personal data under Regulation (EU) 2018/1725.
- The European Data Protection Supervisor (EDPS)
You have the right to have recourse (i.e. you can lodge a complaint) to the European Data Protection Supervisor (edps@edps.europa.eu) if you consider that your rights under Regulation (EU) 2018/1725 have been infringed as a result of the processing of your personal data by the data controller.
10. Where to find more detailed information?
The Commission Data Protection Officer (DPO) publishes the register of all processing operations on personal data by the European Commission, which have been documented and notified to him. You may access the register via the following link: http://ec.europa.eu/dpo-register.
This specific processing operation has been included in the DPO’s public register with the following Record reference: DPR-EC-09286.
