Flexitime interface-PersonaGrata - Council

Opinion of 16 September 2008 on the notification for prior checking regarding the "Flexitime interface-PersonaGrata (DGA3) dossier (Case 2008-324)

This prior check by the European Data Protection Supervisor is the first to be based on Article 27(2)(c), which provides for the prior checking of "processing operations allowing linkages not provided for pursuant to national or Community legislation between data processed for different purposes". The purpose of the interface between Flexitime and PersonaGrata at the Council is to make it possible to prevent duplication of the work of encoding data considered as equivalent between the two databases with the dangers of error that that entails, and thus to ensure consistency between the two databases, improve the efficiency of personnel management in the departments and units and to provide more reliable information. As regards the clocking data, the purpose of the interface is to export those data from the Flexitime database to the PersonaGrata system.

The EDPS' main recommendations for the interface between Flexitime and PersonaGrata concern compliance with the rules laid down for the Flexitime case (including those on the provision of information to data subjects and the data storage period), to maintain consistency between these two cases. The EDPS also asks that there should be a specific procedure for saving data in connection with that interface.