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Processing of personal data by social services - Court of Auditors

8
Nov
2007
Opinions Prior Check and Prior Consultations

Processing of personal data by social services - Court of Auditors

Opinion of 8 November 2007 on a notification for prior checking on processing of personal data by the social services (Case 2007-302)

The Social Service of the Court of Auditors is provided by a professionally qualified social worker who is responsible for the provision of social financial assistance and psychosocial support. Types of assistance include home help, assistance for disabled officials or disabled dependents of officials, loans and aid granted on social grounds (special assistance in extreme circumstances). The social worker also offers psychosocial support to officials and their families, retired officials, and the surviving family members of deceased officials. The social worker also provides practical assistance chiefly in the form of information as to the availability of resources and services in specific areas.
 
As a rule, the relevant data are compiled by the social worker in an interview with the applicant. In certain cases, the applicant is requested to complete certain forms. If need be, medical approval is sought from the Medical Service or from the JSIS's medical officer. A decision, drawn up by the social worker, is submitted to the Appointing Authority (Head of Division, Human Resources) for signature and the beneficiary is informed of the decision.
 
When the social worker meets with the client, personal and private data are compiled in a personal record, which is only accessible to the social worker. The social worker is bound by professional secrecy and that all conversations will be confidential. The social worker may make personal notes concerning the client's situation as a memory aid and for future reference. Any documentation in the file supplied by the applicant remains the property of the applicant and, on request, may be returned to the persons concerned.
 

The EDPS opinion concluded that the processing proposed does not seem to involve any infringement of Regulation (EC) No 45/2001, as long certain recommendations are taken into account and notably that the Court of Auditors assesses the period of conservation of short term assistance; that the Court of Auditors ensures, in compliance with Article 4(1)(e) that the data stored in Excel tables for statistical and record-keeping purposes are kept in an anonymous form or with the identity of the data subject encrypted; and that further information must be provided to data subjects in accordance with Articles 11 and 12.

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