Ref. Ares(2023)892878 - 07/02/2023
EUROPEAN COMMISSION
DIRECTORATE-GENERAL
ENVIRONMENT
Directorate B - Circular Economy
ENV.B.2 – Safe and Sustainable Chemicals
Laura Döring
1 Long Lane
Borough
London
UK
By email: ask+request-12133-
xxxxxxxx@xxxxxxxx.xxx
Dear Ms Döring,
Subject: Your application for access to documents: Ref EASE No 2022/6555
We refer to your request for access to documents dated 10 November 2022, registered
under the above-mentioned reference number, and to our holding reply Ares
(2022)8384583. We would like to sincerely apologise for the delay in our reply.
You requested access to the following:
“
All documentation (including but not limited to all email correspondence, attendance
lists, agendas, background papers, transcripts, recordings and minutes/notes) relating to
the meetings listed below:
1. Between European Chemical Industry Council and Florika Fink Hooijer, Director
General on 07/09/2021
2. Between European Chemical Industry Council and Florika Fink Hooijer, Director
General on 27/01/2021”.
Your application concerns the following documents:
1. Between Florika Fink-Hooijer (Director-General) and Cefic on 7th
September 2021
Title
Author
Addressee
Date
Reference Ares
1.
E-mail
CEFIC
COM
13/07/2021
Ares(2023)769184
exchange
2.
Letter
Cefic
COM
29/07/2021
Ares(2022)7489419
3.
Meeting
DG ENV
DG ENV
Ares(2022)7650552
flash
report
Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË - Tel. +32 2299
2. Between Florika Fink-Hooijer (Director-General) and Cefic on 27th January
2021
Title
Author
Addressee
Date
Reference Ares
4.
Meeting
DG ENV
DG ENV
29/01/2021
Ares(2022)7847155
report
A complete disclosure of the documents is 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, because it contains the following personal data:
-
the names and contact information of Commission staff members not pertaining to
the senior management;
-
the names and contact details of other natural persons;
-
handwritten signatures of other natural persons
In your application, you indicate that your address is in the United Kingdom. Transfers of
personal data from the Commission to countries that are not members of the European
Economic Area (EEA), or to international organisations are regulated under Chapter V of
the Data Protection Regulation1.
According to Article 47(1) of this Regulation, a transfer of personal data to a third
country or an international organisation may take place where the Commission has
decided that the third country, a territory or one or more specified sectors within that
country, or the international organisation in question ensures an adequate level of
protection and where the personal data are transferred solely to allow tasks within the
competence of the controller to be carried out. Based on the information available, the
country of your residence is recognised by the Commission as ensuring an adequate level
of protection. However, we would further like to inform you that 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 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.
1 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, and repealing Regulation (EC) No
45/2001 and Decision No 1247/2002/EC, OJ L 295, 21.11.2018, p. 39.
2
Please note that document 2 and the part of document 1 originating from third parties are
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 documents without the agreement of the originator, who
may hold an intellectual property right on them. The European Commission does not
assume any responsibility from their reuse.
Please also note that documents 3 and 4 were drawn up for internal use under the
responsibility of the relevant officials of the Directorate-General for Environment. They
solely reflect the authors’ interpretation of the interventions made and do not set out any
official position of the third parties to which the documents refer, which were not consulted
on its content. They do 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:
by asking for a review via your portal2 account (available only for initial requests
submitted via the portal account),
or by mail:
European Commission
Secretariat-General
Transparency,
Document
Management
&
Access
to
Documents
(SG.C.1)
BERL 7/076
B-1049 Bruxelles
or by email to: xxxxxxxxxx@xx.xxxxxx.xx
Yours sincerely,
Cristina de Avila
Head of Unit
2
https://www.ec.europa.eu/transparency/documents-request
3
Electronically signed on 07/02/2023 16:29 (UTC+01) in accordance with Article 11 of Commission Decision (EU) 2021/2121