7
Sep
2007
Security clearance - European Central Bank
Opinion of 7 September 2007 on a notification for prior checking related to the application of the security clearance rules (Case 2007-371)
This prior check concerns the data processing activities which the ECB carries out in the context of running security clearance procedures in order to ascertain whether or not a person is eligible for a security clearance. Towards this end, the ECB collects and further processes the legal/criminal history related to those who are subject to such procedures which include those selected for employment at the ECB, non-staff members and unescorted visitors who have to move within the premises of the ECB.
In his opinion, the EDPS concluded that the ECB has substantially followed all the principles of the Regulation. Nevertheless the EDPS recommended that the ECB:
- Redefines the nomenclature (mainly with respect to the "certificate of good conduct"), and its definition in order to prevent the collection of information that goes beyond the recollection of criminal convictions.
- Includes a limit in the first question of the self-declaration form so that individuals are not required to provide information on crimes that would not be included in a criminal record. Also, in this question, delete the reference to imprisonments and consider rephrasing the question as suggested in this Opinion.
- Amends the self-declaration form so that traffic offences are excluded from the scope of the question (which asks whether there are criminal cases pending against the individualSets up a system to ensure the effective application of the rectification right and data quality and conservation principles as far as the certificates of good conduct are concerned.
- Amends the privacy statement as recommended in the Opinion.
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