Processing operation: ECI Communication Campaign - interaction with the ECI Ambassadors
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 (…), thereby contributing to promoting the active participation of citizens in the political life of the Union.’
One of the pillars of the ECI communication campaign is a promotion of the ECI through the ECI Ambassadors.
The ECI Ambassadors are active multipliers of the European Citizens’ Initiative, helping to promote the ECI values and messages on the ground, in the EU member states or at EU level. The ambassadors are involved in a variety of activities around the European Citizens’ Initiative, including:
- Disseminating content related to the European Citizens Initiative through their communication channels (website, social media, publications, events etc.)
- Taking part in social media campaigns launched by the European Commission to bring ECI messages closer to citizens and other interested parties
- Support in identifying and engaging key opinion leaders with strong outreach potential (i.e. local celebrities, activists, decision makers, influencers etc.)
- Support with designing, organising and promoting the events within its network
The aim of the collection and processing of your data by Unit SG.A.1, is to allow you to fulfil the role of the ECI Ambassador. This requires the following processing operations:
- Processing of data allowing to qualify you as the ECI ambassador, namely assessments leading to your selection as ECI ambassador
- Processing of your contact details as ECI ambassadors to invite you to take part in ECI communication events
- Collection and/or producing and publishing on the ECI website of your name and surname, function title as well as social media contact details, photo and bio note,
- Monitoring of the Ambassadors’ social media and other promotional activities related to the ECI
Your data will be collected manually, via the contractor (Netcompany – Intrasoft S.A., 2b, rue Nicolas Bové, L-1253 Luxembourg, G.D. Luxembourg, email: eci@netcompany-intrasoft.com).
Your personal data will not be used for an automated decision-making including profiling.
Moreover, the ECI Ambassadors are likely to participate in the other specific activities of the ECI communication campaign** and of the ECI Forum.
Your personal data are thus likely to be processed in the context of other processing operations:
- when ECI ambassadors interact with the Commission and the citizens through the ECI Forum – for details please see the Commission data processing record DPR-EC-00828 and the relevant privacy statement;
- when ECI ambassadors feature in promotional materials of the ECI communication campaign - for details please see the Commission data processing record DPR-EC- 09286 and the corresponding privacy statement concerning ‘Preparation and dissemination of promotional materials of the ECI Communication campaign’;
- when ECI ambassadors participate in the ECI communication campaign events (online and offline), as speakers or participants – for details please see the Commission data processing record DPR-EC-01063 and the privacy statements of the specific event;
- when ECI ambassadors participate in the ECI stakeholders consultations – for details please see the Commission data processing record DPR-EC-01011 and the privacy statement of the specific stakeholder consultation.
Any such processing for other purposes is always subject to a relevant specific privacy statement and, where applicable, to your specific consent.
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**These processing operations are described in the privacy statement concerning ‘ECI Communication campaign published at: https://citizens-initiative.europa.eu/privacy-policy_en
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.’
All the processing operations in the context of the ECI communication campaign are carried out in the public interest in line with the legal obligation put on the Commission in the ECI Regulation.
We collect and process your personal data as ECI stakeholder, and those required to qualify you as the ECI ambassador because the processing for the purpose expressed above under Section 2, point a) (contact details, assessments leading to your selection as ECI ambassador) is necessary for the performance of a task carried out in the public interest.
We collect and process your personal data, as ECI Ambassador, based on your consent (by signing of the ECI Ambassador’s charter), for the purposes expressed above, under Section 2, points b), c) and d).
We ensure that adequate and specific safeguards are implemented for the processing of personal data, in line with the applicable data protection legislation.
We have obtained your consent directly from you, in written form, by signing the ‘Ambassador Charter’.
4. Which personal data do we collect and further process?
We will process your following data, as the ECI Ambassadors:
- Contact details as received from you or sourced from relevant official or Commission databases, existing local Commission or agency relationships and publicly available sources: first name, last name, nationality/language preferences, function/job title, organisation name, phone number, e-mail address, social media account usernames;
- Bio notes and photos you have provided in view of their publication on the ECI website,
- assessments of the Commission and of the contractors leading to the selection as ECI ambassador, views and opinions being part of the exchanges with the Commission and the contractors, ECI ambassador charter signed, reports from the social media and other promotional activities established by the contractor based on the publicly available information.
Other personal data of the ECI Ambassadors may be processed in the context of the other processing operations contributing to the ECI communication campaign, as mentioned under section 2,In particular, if an ECI ambassador provides an individual testimonial on his/her ECI experience as part of the ECI communication campaign or participates in an ECI communication event or in a targeted consultation. Any such other processing will be carried out in accordance with the relevant privacy statement and based on your specific consent, where applicable.
5. How long do we keep your personal data?
Unit SG.A.1 only keeps your personal data for the time necessary to fulfil the purpose of collection or further processing, namely for a maximum period of twelve months after you have ceased to perform the function of the ECI Ambassador.
Documents (reports, correspondence, financial information if relevant etc.) containing personal data will be kept by the European Commission for ten years and archived according to the Commission's legal framework and stored in ARES (Advanced Records System) under the responsibility of Secretariat-General (see record DPR-EC-00536).
Selected audiovisual content may be archived for permanent preservation, in line with the provisions of the Common Commission Level Retention List (SEC(2022)400), for historical purposes to document, preserve and make available the history and audio-visual heritage of the Commission and the European Union.
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 General Data Protection Regulation (‘GDPR’ Regulation (EU) 2016/679). 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.
Your name and surname, function title as well as social media contact details, photo and bio note will be published on the ECI website.
We may share your first name, family name, organisation and contact details with other ECI stakeholders based on ‘need to know’ principle to facilitate the organisation of other campaign activities.
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 or erase your personal data and the right to restrict the processing of your personal data. Where applicable, you also have the right to object to the processing or the right to data portability.
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 related to your enrolment as ECI ambassador. 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, Directorate-General, 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 has been included in the DPO’s public register with the following Record reference: DPR-EC-09286.
