Procedures related to "360° Leadership feedback report" - EIB

Opinion of 20 July 2010 on a notification for Prior Checking concerning procedures related to "360° Leadership feedback report" (Case 2009-0215)

On 20 July 2010, the EDPS adopted an opinion concerning procedures related to "360° Leadership feedback report of the European Investment Bank (EIB).

The 360° Leadership tool is a self-development tool for managers and experts at C-level and above. The purpose of this tool is to allow them to identify their strengths and areas for development. The tool is provided on a voluntary basis, both to those who qualify for enrolment in the program and to those who will provide feedback on their skills.

The EIB decided to deploy its tool in two different steps. In a first phase, called pilot phase, the tool was deployed only among a few EIB directorates. Then, as a second step, the full deployment of the tool within the EIB was foreseen.

Following his established approach as regards pilot projects, the EDPS analysed the procedure implemented in the context of the pilot project and provided specific recommendations relating to the pilot project before its launch. The EDPS also provided recommendations that should be taken into account for the full launch of the tool, in order to avoid any contradictions between the two phases (pilot phase and full launch of the system) that could have an impact on the protection of personal data.

In his conclusions of the prior-check opinion, the EDPS considered that the recommendations made in the analysis of the pilot project had been implemented by the EIB. Based on the foregoing, the EDPS considered that the follow-up of this opinion had been carried out and decided to close the case.