Protection of your personal data
This privacy statement provides information about the processing and the protection of your personal data.
Processing operation: EU Neighbours website
Data Controller: The Directorate-General Neighbourhood & Enlargement Negotiations (DG NEAR) / Unit NEAR.A2 Inter-institutional Relations and Communication
Record reference: [DPR-EC-02019]
Table of Contents
- 1. Introduction
- 2. Why and how do we process your personal data?
- 3. On what legal ground(s) do we process your personal data?
- 4. Which personal data do we collect and further process?
- 5. How long do we keep your personal data?
- 6. How do we protect and safeguard your personal data?
- 7. Who has access to your personal data and to whom is it disclosed?
- 8. What are your rights and how can you exercise them?
- 9. Contact information
- 10. Where to find more detailed information?
The European Commission (hereafter ‘the Commission’) is committed to protect your personal data and to respect your privacy. The Commission collects and further processes personal data pursuant to Regulation (EU) 2018/1725 of the European Parliament and of the Council of 23 October 2018 on the protection of natural persons with regard to the processing of personal data by the Union institutions, bodies, offices and agencies and on the free movement of such data (repealing Regulation (EC) No 45/2001).
This privacy statement explains the reason for the processing of your personal data, the way we collect, handle and ensure protection of all personal data provided, how that information is used and what rights you have in relation to your personal data. It also specifies the contact details of the responsible Data Controller with whom you may exercise your rights, the Data Protection Officer and the European Data Protection Supervisor.
The information in relation to processing operation “EU Neighbours website” undertaken by the Directorate-General for Neighbourhood and Enlargement Negotiations / Unit NEAR.A2 Inter-institutional Relations and Communication, is presented below.
2. Why and how do we process your personal data?
Purpose of the processing operation: The Directorate-General Neighbourhood & Enlargement Negotiations / Unit NEAR.A2 Inter-institutional Relations and Communication collects and uses your personal information for the purposes of the visibility and promotion of EU-funded projects and programmes in the Eastern and Southern Neighbourhood countries (Armenia, Azerbaijan, Belarus, Georgia, Republic of Moldova and Ukraine; Algeria, Egypt, Israel, Jordan, Lebanon, Libya, Morocco, Palestine1, Syria and Tunisia) through personal invitations to events, and sending of notifications and news alerts about the EU-funded programmes and projects and EU-related opportunities in the Eastern Partnership and in the Middle East and North Africa (MENA) region.
All data processing is transparent and abides by the principle of users opting-in/out, and allowing the data they provide to be used for specific purposes.
Your personal data will not be used for an automated decision-making, including profiling.
3. On what legal ground(s) do we process your personal data
We process your personal data because the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Union institution or body (Article 5 (a) of Regulation (EU) 2018/1725);
The basis for the processing is laid down by the following Union law: Article 11 of the consolidated European Treaty on the European Union states: “The institutions shall, by appropriate means, give citizens and representative associations the opportunity to make known and publicly exchange their views in all areas of Union action. The institutions shall maintain an open, transparent and regular dialogue with representative associations and civil society”.
Article 21(1) of the Treaty on European Union (TEU): overall mandate and guiding principles in the field of EU development cooperation; Articles 4(4) and 208 to 211 of the Treaty on the Functioning of the European Union (TFEU).
In addition, the processing is necessary for the fulfilment of the European Commission's obligation to ensure visibility of the Union’s financial support, as stipulated in Article 4(5) of Regulation (EU) No 236/2014 of the European Parliament and of the Council of 11 March 2014 laying down common rules and procedures for the implementation of the Union’s instruments for financing external action, OJ L 77, 15.3.2014.
Where data are not marked as mandatory, DG NEAR processes your personal data based on your consent (Article 5 (d) of Regulation (EU) 2018/1725). All data processing is transparent and abiding by the principle of users’ opting-in/out, and allowing the data they provide to be used for specific purposes.
We do not process special categories of personal data (Article 10 of the Regulation (EU) 2018/1725.
4. Which personal data do we collect and further process?
In order to carry out this processing operation the Directorate-General for Neighbourhood and Enlargement Negotiations / Unit NEAR.A2 Inter-institutional Relations and Communication collects the following categories of personal data:
- First name,
- Last name,
- Date of birth*,
- Topic of Interest,
- Country of Interest,
- Notification language,
- E-mail address,
- Postal address*,
- Country of origin
* are not mandatory fields
Your data might be collected by means of the news alert registration interface in which the data subjects enter their data directly.
Data subjects unambiguously give their consent to the processing of the personal data when filling the online subscription form. The data could also be collected from other sources, including lists of participants in related events, topic-related databases, as well as various public sources.
5. How long do we keep your personal data?
The Directorate-General for Neighbourhood and Enlargement Negotiations / Unit NEAR.A2 Inter-institutional Relations and Communication only keeps your personal data for the time necessary to fulfil the purpose of collection or further processing.
Data will be kept as long as the data subject is registered and for as long as the website operates as a tool of DG NEAR's promotion policy. Some parts of the data might be kept for a longer period where stipulated by financial authorities (10 years in case of financial transactions) or for auditing purposes (usually 7 years). Data will be automatically removed at the end of the respective period or when no longer needed. Information will be anonymised within one month from the date of submission of the Unregistration Request.
6. How do we protect and safeguard your personal data?
All personal data in electronic format (e-mails, documents, databases, uploaded batches of data, etc.) are stored either on the servers of the European Commission or of its contractors. All processing operations are carried out pursuant to the Commission Decision (EU, Euratom) 2017/46 of 10 January 2017 on the security of communication and information systems in the European Commission.
The Commission’s contractors are bound by a specific contractual clause for any processing operations of your data on behalf of the Commission, and by the confidentiality obligations deriving from the transposition of the General Data Protection Regulation in the EU Member States (‘GDPR’ Regulation (EU) 2016/679.]
In order to protect your personal data, the Commission has put in place a number of technical and organisational measures in place. Technical measures include appropriate actions to address online security, risk of data loss, alteration of data or unauthorised access, taking into consideration the risk presented by the processing and the nature of the personal data being processed. Organisational measures include restricting access to the personal data solely to authorised persons with a legitimate need to know for the purposes of this processing operation.
The collected personal data and all information related are stored on the servers of the Processors during the implementation and the maintenance of the website.
Personal data in electronic form: access to your personal data, as well as any other information collected in the website is exclusively provided through an identification system with password, accessible to a restricted number of users, without prejudice of a possible future transmission of these data to the bodies charged with the control and inspection of the Commission's activities in conformity with EU law. These users are the Units of DG NEAR, as well as officially contracted external companies.
7. Who has access to your personal data and to whom is it disclosed?
Access to your personal data is provided to the Commission staff responsible for carrying out this processing operation and to authorised staff according to the “need to know” principle. Such staff abide by statutory, and when required, additional confidentiality agreements.
The Data Controller and its Processors have access to your personal information. The Processors are either:
- Staff of DG NEAR's contractor in charge of the communication services, which manage the collected personal data and conduct ad hoc satisfaction surveys;
- staff of DG NEAR's contractors providing web services for the DG NEAR website www.euneighbours.eu (such as website design, website hosting including cloud services etc.).
DG NEAR's contractors use the Mandrill e-mailing platform for sending the news alerts to the data subjects. Mandrill commits to meeting the GDPR requirements and has a retention policy of 30 days on data stored on its servers.
Further access may be granted on a need to know basis to EU Institutions (including the Commission, EU Delegations in third countries etc.).
No personal data is transmitted to parties, which are outside the recipients and the legal framework mentioned. The data are solely collected and further processed for the specific purposes mentioned in this privacy statement and shall not be used for any other purpose.
Any recipient shall be reminded of its obligation not to use the data received for other purposes than the one for which they were transmitted.
8. What are your rights and how can you exercise them?
You have specific rights as a ‘data subject’ under Chapter III (Articles 14-25) of Regulation (EU) 2018/1725, in particular the right to access, your personal data and to rectify them in case your personal data are inaccurate or incomplete. Where applicable, you have the right to erase your personal data, to restrict the processing of your personal data, to object to the processing, and the right to data portability.
You have the right to object to the processing of your personal data, which is lawfully carried out pursuant to Article 5(1)(a) on grounds relating to your particular situation.
You have consented to provide your personal data to the Directorate-General Neighbourhood & Enlargement Negotiations / Unit NEAR.A2 Inter-institutional Relations and Communication for the present processing operation. You can withdraw your consent at any time by notifying the Data Controller. The withdrawal will not affect the lawfulness of the processing carried out before you have withdrawn the consent.
You can exercise your rights by contacting the Data Controller, or in case of conflict the Data Protection Officer. If necessary, you can also address the European Data Protection Supervisor. Their contact information is given under Heading 9 below.
Where you wish to exercise your rights in the context of one or several specific processing operations, please provide their description (i.e. their Record reference(s) as specified under Heading 10 below) in your request.
9. Contact information
- The Data Controller
If you would like to exercise your rights under Regulation (EU) 2018/1725, or if you have comments, questions or concerns, or if you would like to submit a complaint regarding the collection and use of your personal data, please feel free to contact the Data Controller, Directorate-General Neighbourhood & Enlargement Negotiations / Unit NEAR.A2 Inter-institutional Relations and Communication, using the functional mailbox NEAR-A2@ec.europa.eu.
- The Data Protection Officer (DPO) of the Commission
You may contact the Data Protection Officer (DATA-PROTECTION-OFFICER@ec.europa.eu) with regard to issues related to the processing of your personal data under Regulation (EU) 2018/1725.
- The European Data Protection Supervisor (EDPS)
You have the right to have recourse (i.e. you can lodge a complaint) to the European Data Protection Supervisor (firstname.lastname@example.org) if you consider that your rights under Regulation (EU) 2018/1725 have been infringed as a result of the processing of your personal data by the Data Controller.
10. Where to find more detailed information?
The Commission Data Protection Officer (DPO) publishes the register of all processing operations on personal data by the Commission, which have been documented and notified to him. You may access the register via the following link: http://ec.europa.eu/dpo-register.
This specific processing operation has been included in the DPO’s public register with the following Record reference: DPR-EC-02019.
1 This designation shall not be construed as recognition of a State of Palestine and is without prejudice to the individual positions of the Member States on this issue.