EUROPEAN COMMISSION
DIRECTORATE-GENERAL FOR COMPETITION
Policy and Strategy
Brussels, 20/12/2021
COMP/A/ HLG
Mrs Lora Verheecke
Rue du Bronze 9
1070 Brussels
Subject: Your application for access to documents – Ref GestDem No 2021/6639
Dear Madam,
We refer to your e-mail dated 8 November 2021 in which you make a request for access to
documents, registered on 10 November 2021 under the above mentioned reference number.
In your email you request all documents, including but not limited to correspondence (including
email and letters) containing substantive discussion relevant to the meeting, attendance lists,
agendas, background papers, transcripts, recordings, minutes, notes, and meeting conclusions
relating to the Olivier Guersent’s participation in the CDFP event of 16 March 2021.
Your application concerns the following document/documents with the Commission:
Email with attached invitation by Cercle des Délégués Permanents Français to Olivier Guersent
dated 25 January 2021;
A Cercle des Délégués Permanents Français brochure attached to the above email;
Email exchange between Cercle des Délégués Permanents Français and Olivier Guersent’s
assistant regarding Mr Guersent’s intervention dated 26/01/2021, 18/02/2021, 19/02/2021,
26/02/2021, 01/03/2021 and 8/3/2021 respectively (one document);
Briefing prepared for Olivier Guersent for the event, and
Email and attached thank you letter from Cercle des Délégués Permanents Français to Olivier
Guersent dated 05/04/2021.
All emails and letters as well as the briefing prepared for Olivier Guersent contain personal data and a
complete disclosure of the identified documents is therefore prevented by the exception concerning the
protection of privacy and the integrity of the individual outlined in Article 4(1)(b) of Regulation (EC)
No 1049/2001, i.e. it includes:
Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË - Tel. +32 22991111
Office: MADO 04/016 - Tel. direct line +32 229-61011
xxxx.xxxxxxx@xx.xxxxxx.xx
- the names/initials and contact information of Commission staff members not pertaining to
senior management;
- the names/initials and contact details of other natural persons;
- handwritten signatures/abbreviated signatures of natural persons;
Article 9(1)(b) of the Data Protection Regulation does not allow the transmission of these personal
data, except if you prove that it is necessary to have the data transmitted to you for a specific purpose
in the public interest and where there is no reason to assume that the legitimate interests of the data
subject might be prejudiced. In your request, you do not express any particular interest to have access
to these personal data nor do you put forward any arguments to establish the necessity to have the data
transmitted for a specific purpose in the public interest.
Consequently, I conclude that, pursuant to Article 4(1)(b) of Regulation (EC) No 1049/2001, access
cannot be granted to the personal data contained in the requested documents, as the need to obtain
access thereto for a purpose in the public interest has not been substantiated and there is no reason to
think that the legitimate interests of the individuals concerned would not be prejudiced by disclosure of
the personal data concerned.
Please note that the attached includes information originating from third parties and is disclosed to
you based on Regulation (EC) No 1049/2001. However, this disclosure is without prejudice to the
rules on intellectual property, which may limit your right to reproduce or exploit the released
document/documents without the agreement of the originator, who may hold an intellectual property
right on it/them. The European Commission does not assume any responsibility from their reuse.
Please note that the briefing note prepared by DG COMP for Mr Guersent reflects the authors’
interpretation and summaries of third party content and does not set out any official position of the
third parties to which the document refers, which was not consulted on its content. It further does not
reflect the position of the Commission and cannot be quoted as such.
In case you would disagree with this position, you are entitled, in accordance with Article 7(2) of
Regulation (EC) No 1049/2001, to submit a confirmatory application requesting the Commission to
review this position.
Such a confirmatory application should be addressed within 15 working days upon receipt of this letter
to the Secretariat-General of the Commission at the following address:
European Commission
Secretariat-General
Unit C.1. ‘Transparency, Document Management and Access to Documents’
BERL 7/076
B-1049 Brussels, or by email to:
xxxxxxxxxx@xx.xxxxxx.xx
Yours faithfully,
[e-signed]
Koen VAN DE CASTEELE
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