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

Pages

20/04/2005
20
Apr
2005

Staff appraisal - European Central Bank

Opinion of 20 April 2005 on the notification for prior checking relating to the Staff Appraisal procedure (Case 2004-274)

20/04/2005
20
Apr
2005

Dignity at work - European Investment Bank

Opinion of 20 April 2005 on the notification for prior checking relating to the Dignity at Work Policy (Case 2004-67)

06/04/2005
6
Apr
2005

Medical expenses - European Investment Bank

Opinion of 6 April 2005 on the notification for prior checking relating to procedures regarding the administrative management of medical expenses (Case 2004-305)

04/04/2005
4
Apr
2005

Skills inventory - Council

Opinion of 4 April 2005 on the notification for prior checking relating to the Skills Inventory (Case 2004-319)

21/03/2005
21
Mar
2005

Disciplinary files - Parliament

Opinion of 21 March 2005 on the notification for prior checking relating to data processing in the context of disciplinary files (Case 2004-198)

03/03/2005
3
Mar
2005

"RAPNOT" - Parliament

Opinion of 3 March 2005 on the notification for prior checking relating to the reports procedure and the RAPNOT system (Case 2004-206)

04/02/2005
4
Feb
2005

"EPES" - Commission

Opinion of 4 February 2005 on the notification for prior checking relating to the appraisal of senior management staff (Case 2004-95)

28/01/2005
28
Jan
2005

Work rates - Commission

Opinion of 28 January 2005 on the notification for prior checking relating to work rates ("Rythme de travail") (Case 2004-96)

06/01/2005
6
Jan
2005

Selection procedure for temporary agents - OHIM

Opinion of 6 January 2005 on the notification for prior checking relating to an internal selection procedure for temporary agents (Case 2004-174)

21/12/2004
21
Dec
2004

"Top 50" - Parliament

Opinion of 21 December 2004 on the notification for prior checking relating to the procedure "TOP 50" (Case 2004-126)

21/12/2004
21
Dec
2004

Processing by Eurostat - Commission

Opinion of 21 December 2004 on a notification for prior checking on Eurostat's data processing operation in order to carry out actuarial calculation for European civil service pension scheme (Case 2004-196)

04/05/2004
4
May
2004

Processing on traffic data - European Parliament

Opinion of 4 May 2004 on a notification for prior checking (Case 2004-13)

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