Management of absences and sickness leave - EESC

Opinion of 5 March 2010 on a notification for prior checking on the management of absences and sickness leave using the "Centurio" database (Joint cases: 2009-0702 and 2009-0703)

This prior checking covers the data protection aspects of the management of absences and sickness leave at the EESC and the operation and use of the "Centurio" IT system for this purpose. The EDPS opinion focuses on special leave, medical leave and maternity leave but when necessary also addresses other aspects of the management of absences.

The EDPS recommendations focus on data retention and proportionality/access rights.

In particular, the EDPS recommends that EESC should shorten the retention period for medical leave (to four from five years). EESC should also reconsider the retention period, on a case by case basis, for each other type of leave for which the retention period is currently also set at five years. In most cases, a retention period not exceeding one or two years may be appropriate.

Further, EESC should reconsider the rules governing who has access to what data and for what period of time. In particular, access to management should be limited to a lesser set of categories and for a shorter period of time, not including historic data. Access to assistants and others upon authorization by the heads of units should also be more limited. Medical service should only have access to medical leave data and not to other types of leave data. Their access to historic data should also be reconsidered. Further, in the staff directory, which is available for all for viewing on the EESC intranet, there is no need to indicate whether an individual is on a temporary contract or a permanent official and whether he is in or out of the office on a particular day. Finally, photos should be uploaded only based on clear opt-in consent.