Print

IT at Work

Filters

6
Feb
2008
Opinions Prior Check and Prior Consultations

Identity Management Service - Commission

Opinion of 6 February 2008 on a notification for prior checking realted to the Identity Management Service (Case 2007-349)

DIGIT provides the Identity Management Service (IMS), a service used primarily to manage user populations and their rights in the context of information services. In particular, IMS facilitates the authentication and access control of users to different Commission information services, which are managed by different Directorates General. In doing so, IMS customizes user's interfaces according to user's individual characteristics. IMS is used for Commission staff as well as for personnel of other organizations and members of the public. 
 
The EDPS recommendations to be implemented by DIGIT include, inter alia,
 
(i) obtain users' consent to process data processed through IMS for customization purposes (interactively and on screen, for example, using the technique of a "pop up" window). 
(ii) consider shortening the data retention deadlines for log files
(iii) put in place a system that ensures the accuracy of personal information of non Commission staff members who have been registered in IMS by third parties such as their employers. 
(iv) amend the privacy statement and ensure its display before the use of IMS as well as the possibility to consult it at any time
Available languages: English
Topics
Privacy in the EU Institutions
IT at Work
18
Jul
2007
Opinions Prior Check and Prior Consultations

Silent monitoring - OHIM

Opinion of 18 July 2007 on a notification for prior checking on silent monitoring (Case 2007-128)

The processing operations consist in the selective monitoring of incoming phone calls processed by the Information Centre Sector. Incoming phone calls are firstly caught by the Switchboard of OHIM. Depending on the subject of the call, the Switchboard puts the call through either to a specific person in OHIM or to the Information Centre, which is competent to address general issues or further put the call through to a specific person in OHIM.
 
During a “Silent Monitoring” exercise, incoming callers are firstly asked for their prior consent to participate in the monitoring exercise. Upon their consent, a third party, namely the responsible person in the Information Centre Sector, is silently listening to the conversation. While a call is monitored, a background signal is continuously emitted so that both the caller and the Switchboard or Information Centre are aware that the call is monitored by a third person. The call is not further monitored when it is put through to a specific person in OHIM. 

Therefore, the purposes of the processing operations referred to in the present notification for prior check, are to assess the quality of the service provided by the Switchboard and by the Information Centre as follows:

  • Switchboard: Quality control and improvement of services in compliance with the Service Level Agreement concluded with the external provider (contractor).
  • Information Centre: Quality control, improvement of services, staff appraisal.  

The EDPS has issued an opinion on this procedure which 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 mainly as concerns avoidance of the use of Article 5(c) of the Regulation as the basis for lawfulness regarding the processing operation conducted vis-à-vis the Switchboard. On the contrary, Article 5(a) of the Regulation has to be used in this regard. Furthermore, a method to guarantee the accuracy of the data should be found. This could be done either by recording the monitored calls or by sharing with the data subject the results of the monitoring in an immediate manner (e.g. after each day of the monitoring exercise), in such a way that the results are documented and discussed as soon as possible after the listening.

Available languages: English
Topics
Privacy in the EU Institutions
IT at Work