Recruitment - European Medicines Agency

Opinion of 19 June 2008 on the notification for prior checking regarding EMEA's "Access" recruitment database and selection and recruitment procedures (Case 2007-422)

This opinion concerns the selection and recruitment organized at the EMEA. The recommendations of the EDPS include the following:

Regarding proportionality, the questions relating to past convictions should be limited in time to those which actually appear on the applicant's criminal record at the time of applying for the position. As for optional data entries, EMEA should more clearly indicate on the application form the provision of what information is optional. Concerning psychometric testing, should EMEA continue to use psychometric testing as part of its selection procedures, it should submit this aspect of the recruitment procedure for prior checking by the EDPS. As regards the conservation of the data, EMEA should reconsider the conservation periods to ensure that data are kept no longer than necessary for the purposes initially contemplated. In particular, when data are conserved for budgetary discharge, control and audit purposes, personal data contained in supporting documents shall be deleted where possible when those data are not necessary for these purposes. Special attention should be paid to highly sensitive data such as information regarding disability and criminal records. As for rights of access, EMEA should revise its procedures to ensure that no access request is turned down merely because it is not submitted on the form specified. Further, EMEA should reconsider the restrictions it has put in place in order to preserve the confidentiality of the deliberations of the selection panel in view of reconciling this interest with the candidates’ right of access. Regarding information to data subjects, specific notice should be provided with respect to all items under Article 11 and 12 of the Regulation in a specific and clear manner, in addition to the availability of EMEA's general “Data Protection Declaration”.