Opinion of 18 May 2009 on the notification for prior checking concerning the promotion and regrading procedure case (Case 2009-018)
The prior checking relates to the processing of personal data in the context of the Translation Centre's promotion/regrading procedure. The procedure is based on an individual promotion/regrading form which is circulated between the different groups of users concerned. The promotion/regrading forms might also be transferred to other Community institutions and agencies if an official/temporary staff member transfers, or applies for a transfer, to another institution/agency. There is also a promotion file composed of individual promotion/regrading forms, the list of officials and temporary staff members eligible for promotion/regrading and the list of officials promoted. The promotion files are kept until officials/temporary staff members (or their dependants) have exhausted all channels of appeal after termination of service and for no longer than ten years as from the last pension payment.
After examining the case, the EDPS reached the conclusion that only relevant data should be stored in the data subject's personal file; that only relevant data should be transferred to another institution in the event of the data subject's transfer there; and that the specific information note should include the general information headings.
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