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22
Oct
2008
Opinions Prior Check and Prior Consultations

eHest training - Council

Opinion of 22 October 2008 on the notification for prior checking regarding eHEST training (Computer based Hostile Environment Security Training) (Case 2008-387)

The Directorate Security Office of the Council organises a specific training in order to raise the security awareness and to mitigate risks for all personnel deployed on EU-led missions outside the EU in an operational capacity under Title V of the EU Treaty.
 
The training, called "eHEST" is a web-based training application with an automated evaluation function. Users are required to submit their data as part of the online registration process. The eHEST training programme envisages three tests. Only if the two first tests are passed with success, the final test can be accessed. The final test leads to certification which is a condition to the deployment in some areas.
 

The EDPS has issued an opinion relating to the processing of personal data in the context of the eHEST training. The EDPS concludes that on a general basis the procedure complies with the principles established in the data protection regulation. However the EDPS did make some recommendations as concerns the conservation of data and the information of the data subjects.

Available languages: English, French
Topics
Privacy in the EU Institutions
Staff Evaluation
1
Oct
2008
Opinions Prior Check and Prior Consultations

Pilot project on individual productivity monitoring - Council

Avis du 1er octobre 2008 sur la notification de contrôle préalable au sujet d'un projet pilote sur le suivi de la productivité individuelle: traitement ultérieur des données à caractère personnel dans l'application Workflow (Dossier 2008-436)

In view of providing Heads of Language Units and individual members of staff with individual performance indicators, the Council intends to set up a pilot project on Individual Productivity Monitoring.
 
The proposed tool should enable individual members of staff to monitor their own production and the head of the data subject's unit to monitor the production of any given member of their unit and to monitor the production of all members of their unit in one simple operation.
 
On the basis of actual output as compared to the actual working time spent on translation and revision (core activities), an objective picture of individual performance can be established on the basis of:  
  1. Comparable statistical data regarding the core activity of linguists, i.e. translation and revision, so that the average translation and revision output of each individual linguist can be compared with the unit average
  2.  A break-down of the actual use of working hours on the one hand by individual linguists and on the other hand at the unit level.  
The productivity reports will be generated monthly, quarterly, half-yearly and yearly. The data produced in this way will be used by the head of the data subject's unit and the individual members of staff as one element in the assessment of the production of each member of staff.
 
A full implementation of the final processing is envisaged around September 2009 after the successful completion of the pilot project.
 
The EDPS concluded that there was no reason to believe that there is a breach of the provisions of Regulation 45/2001 provided certain considerations are fully taken into account. In particular, should the pilot project become a full fledged project at the term of the pilot project, a legal decision/instrument providing a specific legal basis for the processing of personal data must be adopted; the information note on the processing of personal data should be completed to include information on the categories of data collected and further processed; the controller should inform the EDPS as to the measures used to make the data anonymous at the end of the two year retention period; and the possibility of a specific revision procedure by data subjects who which to contest the accuracy of the reports prior to the evaluation exercise should be examined.
Available languages: English, French
Topics
Privacy in the EU Institutions
Staff Evaluation
17
Sep
2008
Opinions Prior Check and Prior Consultations

Career mobility - Parliament

Opinion of 17 September 2008 on a notification for prior checking regarding the "Career Mobility" (Case 2008-329)
This prior checking concerns the data processing operations that take place in the context of the processing for career mobility purposes at the European Parliament. The processing is carried out by the Internal Organisation Unit of the DG for Personnel as well as by the Career Counselling and Professional Guidance Service. The Opinion recommends the data controller to implement various data protection safeguards towards ensuring full compliance with Regulation (EC) No 45/2001. Among others, the EDPS suggests setting up storage periods, ensuring that individuals have the right of access to their data and amending the information notice.

Available languages: English, French
Topics
Privacy in the EU Institutions
Staff Evaluation