Processing of personal data in the context of a Quality Process Monitoring - Council

Opinion of 26 July 2010 on a notification for Prior Checking regarding the processing of personal data in the context of a Quality Process Monitoring (Case 2009-0295)

On 26 July, the EDPS adopted an opinion on the processing of personal data in the context of a Quality Process Monitoring at the General Secretariat of the Council (GSC). The particularity of the processing lies in the fact that the GSC decided to deploy its tool in two different steps. In a first phase, called pilot phase which ran for several months, the tool was deployed only among a few language units. Then, as a second step, the full deployment of the tool within the GSC 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.

The purpose of the processing is to systematically evaluate, through sampling, the linguistic and technical quality of documents produced by the Translation Department.  The tool enables individual members of staff to monitor their own performance; the head of the data subject's unit to monitor the performance of any given member of their unit; individual members of staff to compare their own performance with the unit's average; and better planning and monitoring. 

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 GSC. Based on the foregoing, the EDPS considered that the follow-up of this opinion had been carried out and decided to close the case.