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.
Two external providers cooperate with OIB in this exercise: a subcontractor collects individual evaluation responses per line manager through an online questionnaire and automatically generates reports; the contractor provides for individual coaching sessions to the managers. The specific roles and tasks of these two processors should be are clearly mentioned in the data protection statement. The subcontractor’s data centre is located in the United Kingdom. Forwardlooking, the EDPS highlights that future transfers might come under Article 9 of the Regulation requiring an adequate level of protection within the recipient's legal framework for transfers to third countries. In this issue, see pp.12-13 of EDPS Position paper on transfers to third countries and international organisations by EU institutions and bodies.