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.

Filters

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05/09/2017
5
Sep
2017

Remuneration policies and credits - ECB

Prior check opinion regarding remuneration policies and credits to senior officials of significant entities supervised by the ECB (Case 2017-0358)

08/08/2017
8
Aug
2017

Automated vehicle license plate recognition - ECB

Prior check opinion regarding automated vehicle license plate recognition at the European Central Bank (Case 2016-0695)

07/08/2017
7
Aug
2017

Whistleblowing Policy - EIOPA

Prior-check Opinion on EIOPA’s Whistleblowing Policy (Case 2017-0466)

28/07/2017
28
Jul
2017

Office Indoor Climate Survey - CoR

Prior Checking Opinion "Office Indoor Climate Survey" at the Committee of Regions (Case 2017-0676)

Topics:
28/07/2017
28
Jul
2017

Selection procedure - FRA

Prior check opinion regarding selection procedure of the members of the Advisory Panel at the Fundamental Rights Agency (Case 2017-0427)

26/07/2017
26
Jul
2017

360° feedback exercise - EASME

Prior-checking Opinion regarding 360° feedback exercise for managers in the Executive Agency for Small and Medium-sized Enterprises (Case 2017-0588)

11/07/2017
11
Jul
2017

Whistleblowing Procedure - EP

Prior-checking Opinion on the European Parliaments Whistleblowing Procedure (EDPS case 2017-0379)

07/07/2017
7
Jul
2017

Initial Processing in the event of Whistleblowing - CJUE

Prior Checking Opinion on Initial Processing in the event of Whistleblowing (Case 2017-0304)

27/06/2017
27
Jun
2017

Probation periods - EIF

Prior-checking Opinion regarding probation periods and the e-probation tool at the European Investment Fund (Case 2015-1107)

21/06/2017
21
Jun
2017

Whistleblowing procedure - EDA

Prior check opinion on EDA’s Whistleblowing procedure (Case 2017-0381)

12/06/2017
12
Jun
2017

Selection, recruitment and administrative management of contract agents - EEAS

Prior-checking Opinion regarding selection, recruitment and administrative management of contract agents in EU Delegations (Case 2016-0770)

12/06/2017
12
Jun
2017

Recruitment and administrative management of contract agents - EEAS

Prior-checking Opinion regarding selection, recruitment and administrative management of contract agents in EU Delegations (Case 2016-0770)

07/06/2017
7
Jun
2017

Video-surveillance - GSA

Prior-checking Opinion regarding video-surveillance at the GSA headquarters (Case 2016-1052)

04/04/2017
4
Apr
2017

360° tool - feedback and leadership competencies - EC/OIB

Prior check opinion on the notification of the OIB’s "360° tool - feedback and leadership competencies” (Case 2016-1130 / DPO-3868.1)

The Office for Infrastructure and Logistics in Brussels (OIB) has a development programme for managers using a 360° feedback tool. Managers participate on a voluntary basis in the exercise, in which their staff members, peers and superiors who agree to give feedback get to rate the manager. This allows managers to obtain anonymous feedback on their management and leadership style and to improve their management and leadership skills.

04/04/2017
4
Apr
2017

Internal mobility - EIF

Prior-checking opinion regarding internal mobility at the European Investment Fund (Case 2015-1102)

04/04/2017
4
Apr
2017

Promotion and reclassification - EMSA

Prior checking notification concerning promotion and reclassification at the European Maritime Safety Agency (Case 2016-0396)

03/04/2017
3
Apr
2017

Whistleblowing policy - ENISA

Prior-check Opinion on ENISA’s Whistleblowing Policy (Case 2017-0109)

03/04/2017
3
Apr
2017

Grants Award and Management - REA

Notification concerning “Grants Award and Management by the REA (Research Executive Agency) in the context of the Seventh Framework Programme for Research (FP7) - (Case 2013-1306)

29/03/2017
29
Mar
2017

Whistleblowing Procedure - EUIPO

Prior-check Opinion on EUIPO Whistleblowing Procedure (Case 2016-1056)

28/03/2017
28
Mar
2017

360° Feedback Exercise - F4E

Prior-checking Opinion regarding 360° feedback exercise for managers at Fusion for Energy (Case 2016-0535)

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