Privacy in the EU Institutions

Answer to a notification for prior checking relating to "ETF Contacts management" (Case 2009-038)

Answer to a notification for prior checking on site management and security (Case 2009-036)

Opinion of 10 March 2009 on the notification for prior checking concerning the "end-of-probation procedure" case (Case 2008-720)

Opinion of 26 February 2009 on a notification for prior checking regarding ETF - Flexitime procedure (Case 2008-697)

The European Training Foundation (ETF) has implemented a Flexitime system using RFID technology to ensure equal and fair treatment on a flexible working approach with a view to supporting staff to better conciliate work and private life. The procedure is implemented in a guide to Flexitime of the Agency.

The Flexitime system is not to be confused with any access control system. Although one common badge is used both for the entry to the building and for Flexitime, the Flexitime readers and the access control readers are separate machines. The Flexitime system is based on a Lotus database and is linked to other applications such as SIC Leave and SIC Mission.

There is no reason to believe that there is a breach of the provisions of Regulation (EC) No 45/2001, given that the ETF implements specific recommendations. These deal, among others, with the modification of the conservation period for data relating to audit trail, the introduction of a procedure by which the blocking of data could be ensured in case of complaint, the introduction of stronger security measures on the card and the reconsideration by ETF of its technological choice in terms of security.

Opinion of 23 February 2009 on the notification for prior checking on the "Staff Guidance and Reinstatement Group" (Case 2008-746)

The Council has set up a multidisciplinary group composed of the medical officer, examining doctor, welfare officer, psychologist, a member of the Careers and Development of Competencies Unit, a member of the Staffing and Mobility Unit and the Head of the Social Unit in order to prevent conflicts in the workplace and resolve individual professional problems at the written request of a member of staff.

The Supervisor, having examined how the Group operates in relation to the protection of personal data, has concluded that the provisions of Regulation (EC) No 45/2001 are complied with provided that the Council reviews the period of data storage, checks the appropriateness of transfer of data outside the Group on a case by case basis, ensures that only relevant data are transferred, gives fuller information to data subjects and, if necessary, informs other persons whose data are being processed.