Prior-checking Opinion regarding multi-source feedback reviews for managers (360º evaluation) at Directorate for Human Resources and Personnel Administration of the Council of European Union (Case 2018-0170)
The EU High Level Advisers programme in Moldova aims to draw on the experience of expert senior officials in EU Member States to help Moldova meet its commitments related to agreements with the EU. The programme is run by the Commission and the EU Delegation in Moldova. A service provider helps to implement the programme in Moldova. The candidate High Level Advisers are selected by the Commission and the Delegation and after the endorsement by Moldovan authorities are recruited by the service provider. In consultation with the Moldovan authorities, the service provider annually evaluates the High Level Advisers on their performance. Following this, the Delegation decides whether to extend the High Level Advisers' contracts. All this entails the processing of personal data by the Commission, the Delegation, the service provider and Moldovan authorities.
The Commission and the Delegation are the co-controllers for the processing of personal data in the High Level Advisers programme and need to clearly define their respective obligations. They should also set up a framework for exchanging the personal data of candidate and recruited High Level Advisers with the Moldovan authorities. The Delegation needs to clarify their respective data protection obligations with the service provider. The candidate and recruited High Level Advisers need to be properly informed about how their personal data is processed in the EU High Level Advisers programme in Moldova.