Flexitime - ETF

Opinion of 26 February 2009 on a notification for prior checking regarding ETF - Flexitime procedure (Case 2008-697)

The European Training Foundation (ETF) has implemented a Flexitime system using RFID technology to ensure equal and fair treatment on a flexible working approach with a view to supporting staff to better conciliate work and private life. The procedure is implemented in a guide to Flexitime of the Agency.

The Flexitime system is not to be confused with any access control system. Although one common badge is used both for the entry to the building and for Flexitime, the Flexitime readers and the access control readers are separate machines. The Flexitime system is based on a Lotus database and is linked to other applications such as SIC Leave and SIC Mission.

There is no reason to believe that there is a breach of the provisions of Regulation (EC) No 45/2001, given that the ETF implements specific recommendations. These deal, among others, with the modification of the conservation period for data relating to audit trail, the introduction of a procedure by which the blocking of data could be ensured in case of complaint, the introduction of stronger security measures on the card and the reconsideration by ETF of its technological choice in terms of security.