Processing operation: ECI targeted consultation activities
Data Controller: European Commission
Operational Data Controller: Unit SG.A.1 'Policy Priorities & Work Programme'
Record reference: DPR-EC-01011
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 Targeted consultation activities’ 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 aim of the collection and processing of your personal data in the context of ECI targeted consultation activities, such as surveys, interviews or focus groups is to assess the effectiveness of the ECI communication campaign in raising public awareness about the existence, objectives and functioning of the European citizens’ initiative (…) in accordance with Article 18(1) of the Regulation (EU) 2019/788 of the European Parliament and of the Council of 17 April 2019 on the European citizens' initiative.
ECI targeted consultation activities can also be carried out with the specific purpose of periodically reviewing the functioning of the ECI Regulation in accordance with Article 25 of that Regulation.
For these purposes, Unit SG.A.1 processes the contact details of the relevant and interested ECI stakeholders, 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 as part of the ECI communication campaign – your data are processed in the context of the Commission data processing record DPR-EC-09286,
- 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 proactively entered in contact with the Commission on the subject related to the ECI – your data are processed in the context of the Commission data processing record DPR-EC-01386.
Unit SG.A.1 can also process your personal data in the context of targeted consultation activities via "EUSurvey" to collect feedback from initiatives’ supporters or citizens in general on the European citizens’ initiative in order to inform the Commission’s periodical review of the ECI Regulation. Your data are processed in "EUSurvey" in accordance with the Commission data processing record DPR-EC-01488 on "EUSurvey".
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, the processing of your personal data in the context of ECI targeted consultation activities, such as surveys, interviews or focus groups, always requires your specific consent in accordance with Article 5(1)(d) and 10(2)(a), where relevant, of Regulation (EU) 2018/1725.
4. Which personal data do we collect and further process?
In order to invite you to participate in an ECI targeted consultation activity 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 contacts 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.
If you are proactively taking part in an ECI targeted consultation activity, such as a survey, an interview or a focus group, we will process your answers, contributions and personal views regarding the existence, objectives and functioning of the European citizens’ initiative.
In order to assess the accessibility of the right to support European citizens’ initiatives to persons with disabilities in compliance with Article 2(2) of the ECI Regulation, ECI targeted consultation activities might include, only if necessary and relevant for the above-purpose, questions about your health status or disability and any specific contributions or views you may want to share in this respect. In such a case, providing your answer, contribution and view will be purely optional.
5. How long do we keep your personal data?
Unit SG.A.1 keeps your personal data for the time necessary to fulfil the purpose of collection or further processing of the specific ECI targeted consultation activity, namely for a maximum period of 2 years from your participation in the ECI targeted consultation activity.
6. How do we protect and safeguard your personal data?
All personal data in electronic format (e-mails, documents, databases, uploaded batches of data, 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 transposition of the General Data Protection Regulation in the EU Member States (‘GDPR’ Regulation (EU) 2016/679).
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 contractors’ (Netcompany – Intrasoft S.A and European Citizen Action Service) authorised staff. Such staff abide by statutory, and when required, additional confidentiality agreements.
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).
You have consented to the processing of your personal data in participating to ECI targeted consultation activities, and 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) with regard to 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 is included in the DPO’s public register with the following Record reference: DPR-EC-01011.
