Competence inventory - European Training Foundation
Opinion of 13 June 2007 on a notification for prior checking regarding ETF's competence inventory (Case 2006-437)
This opinion is on the "competence inventory" exercise of the European Training Foundation (ETF) was issued. This complex exercise serves to create a very detailed database listing all relevant competences of each employee. It involves self-assessment, peer-review and moderation by a panel to ensure consistency throughout the ETF. The primary purpose is to obtain aggregate data for strategic management purposes such as to identify competence gaps and adjust recruitment and training polices accordingly.
The EDPS concluded that there are doubts on the proportionality of the establishment of the database and the data quality. For these reasons, the EDPS recommended that ETF reconsiders the necessity of carrying out the competence inventory exercise and look for less intrusive alternatives.
In any event, the EDPS insisted that the database should not result in a parallel performance evaluation system and ETF's management must clearly and explicitly recognise the limitations of the reliability of the data to inform decisions that individually affect data subjects, for example, assessment of applications for internal mobility. Therefore, the data should never be used for pre-selection or exclusion, but only as one of several sources to inform decision-making. Similarly, the competence inventory should not be used for performance appraisal, promotion or assessing contract renewal. Moreover, use of the database should not lead to dismissal, exclusion when tasks are allocated or team leaders and managers are selected, or to similar prejudices to staff members.