European Data Protection Supervisor
European Data Protection Supervisor

Opinions Prior Check

Opinions Prior Check

Some of the procedures that EU institutions put in place pose risks to the data protection rights and freedoms of individuals.

EU institutions are obliged by the Regulation to notify us before putting in place these risky procedures or data processing operations. They are not required to notify us each time the processing takes place.

Article 27(1) of Regulation (EC) No 45/2001 outlines the types of processing that should be notified to us:

  • The processing of certain special categories of data such as health data in pre-recruitment medical exams;
  • The processing intended to evaluate persons such as in staff appraisals, recruitment and selection of staff or contractors under procurement procedures or external experts;
  • Processing which excludes persons from a right, benefit or contract such as blacklisting for project funding;
  • When data is collected for one purpose and potentially used for another without any legal justification (legal basis) for doing so such as linking databases that serve different purposes.

Where an EU institution is unsure whether to notify us, their data protection officer can consult us for advice to confirm.
Once we have received a notification, we issue recommendations as required, to help the EU institutions make the procedure comply with the data protection rules. Our follow up work includes verifying that our recommendations have been implemented by the institution.

In general, our prior checking Opinions are public, but we may delete sensitive elements where necessary, relating to security for example.

On average we receive around 130 such notifications per year.

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19/09/2018
19
Sep
2018

Selection of confidential counsellors and informal procedures for cases of harassment

Prior-checking Opinion regarding the selection of confidential counsellors and informal procedures for cases of harassment at EIF (EDPS cases 2017-1042 and 2017-1043)

 

31/07/2018
31
Jul
2018

Grants management outside the Participant Portal (COSME programme and EMFF) – EASME

Joint Prior-checking Opinion regarding the grants management outside the Participant Portal (COSME programme and EMFF) - EDPS cases 2017-1035 and 2017-1039

31/07/2018
31
Jul
2018

Selection and management of experts outside the Participant Portal (COSME programme and EMFF) – EASME

Joint Prior-checking Opinion regarding the selection and management of experts outside the Participant Portal (COSME programme and EMFF) - EDPS cases 2017-1036 and 2017-1040

24/07/2018
24
Jul
2018

Administrative inquiries and disciplinary proceedings - EBA

Prior-check Opinion on "administrative inquiries and disciplinary proceedings" at EBA (EDPS Case 2017-1083)

19/07/2018
19
Jul
2018

Procedure for the renewal of contracts - EBA

Prior-checking Opinion on the procedure for the renewal of temporary and contract agents’ contracts at EBA (EDPS case 2017-1082)

12/07/2018
12
Jul
2018

Administrative Inquiry Procedures - EIB

Prior-check Opinion on "Administrative Inquiry Procedures” at EIB (EDPS Case 2017-1071)

10/07/2018
10
Jul
2018

Updated notifications for staff appraisal and reclassification - EACEA

Prior-checking Opinion regarding the updated notifications for staff appraisal and reclassification at EACEA (EDPS case 2017-1061 and 2017-1062)

03/07/2018
3
Jul
2018

Reimbursement of medical expenses of Local Agents in EU Delegations – EEAS

Prior-checking Opinion regarding the reimbursement of medical expenses under the Complimentary Sickness Insurance Scheme for Local Agents in EU Delegations (EDPS case 2017-0986)

06/06/2018
6
Jun
2018

Recruitment Procedures - EMSA

Prior-check Opinion on the recruitment procedures at EMSA (Case 2015-0439)

31/05/2018
31
May
2018

Contract renewal procedure at EIOPA

Opinion on the contract renewal procedure at EIOPA (EDPS Case 2017-0769)

23/05/2018
23
May
2018

Processing of Health Data - EIOPA

Prior-checking Opinion regarding the processing of health data at the European Insurance and Occupational Pension Authority (EIOPA) (EDPS case 2017-0284)

25/04/2018
25
Apr
2018

Conduct of investigations - Council

Prior Checking Opinion regarding the conduct of investigations by the Security Office of the General Secretariat of the Council of the European Union (Case 2017-0216)

10/04/2018
10
Apr
2018

Selection of confidential counsellors and informal anti-harassment procedures – EIOPA

Prior-checking Opinion on selection of confidential counsellors and informal anti-harassment procedures at EIOPA (EDPS case 2017-0916)

04/04/2018
4
Apr
2018

EEAS’ processing of personal data for repatriation of EU expatriate staff on medical grounds

Prior-checking Opinion regarding the EEAS’ processing of personal data for repatriation of EU expatriate staff on medical grounds (Case 2016-0778)

22/03/2018
22
Mar
2018

Internal procedures and guidelines on whistleblowing - EMCDDA

Prior-check Opinion on European Monitoring Centre for Drugs and Drug Addiction's (EMCDDA) internal procedures and guidelines on whistleblowing (Case 2016-1083)

21/03/2018
21
Mar
2018

"Data Processing for Social Media Monitoring" at the European Central Bank (ECB) - ECB

Priorcheck Opinion on "Data Processing for Social Media Monitoring" at the European Central Bank (ECB) (Case 2017-1052)

21/03/2018
21
Mar
2018

Whistleblowing procedure in the REA and the relevant internal fraud issues - Case 2014-0178

Prior-check Opinion on “Whistleblowing procedure in the REA and the relevant internal fraud issues” (Case 2014-0178)

21/03/2018
21
Mar
2018

Whistleblowing Rules- FRA

Prior-check Opinion on FRA’s whistleblowing rules (Case 2016-0737)

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