26
Oct
2007
National experts - EMEA
Opinion of 26 October 2007 on a notification for prior checking regarding national expert's expression of interest (Case 2007-423)
The European Medicines Agency (EMEA) collects expressions of interest from national experts to be seconded to the institution. The processing in this framework implies operations such as collection, organisation, storage, consultation and distribution of CVs in order to set up a reserve list of potential candidates. A curriculum vitae must be attached to the applications. The applications received are used for selecting suitable candidates.
On the facts, the collection and further processing of personal data of job applicants is carried out in the legitimate exercise of EMEA's activities and authority. An EMEA Executive Director's Decision laying down the rules on the secondment of national experts constitutes the legal basis of the processing operation.
After examination of EMEA's notification EDPS concludes there is no reason to believe that there is a breach of the provisions of Regulation 45/2001. However, EDPS recommends EMEA should:
- if candidates include data which are irrelevant and excessive in relation with the purposes of the processing, EMEA has to make sure that they are deleted in the most appropriate way.
- publish the Executive Director's Decision on the adoption of implementing rules relating to the protection of individuals with regard to the processing of personal and the free movement of such data of 12 June 2007 on its website,
- adopt and publish a specific policy statement concerning this processing operation which should refer to all the provisions of Article 11.
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