Right to Data Portability / Working Party 29
Dear Justice and Consumers,
Under the right of access to documents in the EU treaties, as developed in Regulation 1049/2001, I wish to address a request to the Working Party 29, which I understand is listed in the register of Commission expert groups as ART29WP:
http://ec.europa.eu/transparency/regexpe...
More specifically, I am requesting any document the Working Party 29 might hold concerning the new Data Portability right (Art. 20) in the upcoming General Data Protection Regulation, that is dated between May 2016 and November 21st 2016.
To the extent they fall under the scope of Regulation 1049/2001, this includes but is not limited to:
- internal discussions of the Working Party 29;
- expert advice obtained by the Working Party 29;
- external enquiries or unsolicited contacts with the Working Party 29 concerning the implementation or interpretation of that right.
In addition, I wish to obtain copies of any documented exchange between the Working Party 29 and Swiss Data Protection Authorities on the topic of Data Portability, dated between May 2016 and the present.
My goal is to understand the diversity of opinions around this Right to Portability, and the different dimensions of this problem to be considered. I wish to access raw documents to make my own opinion, beyond the consensus-driven guidelines that were published.
Depending on how the conversation around the preparation of the Data Portability guidelines (published November 22nd 2016) was structured, this could potentially touch on a very large number of documents. I understand the Working Party 29 is permanently understaffed, and the situation must be worse than usual right now. I am very willing to narrow my request to get access to the documents most relevant to me.
Yours faithfully,
Paul-Olivier Dehaye
PersonalData.IO
Dear Sir,
Thank you for your request for access to documents.
Unfortunately you have not indicated your postal address that is required for registering and handling your request in line with the procedural requirements. Please send us your full postal address at your earliest convenience. Pending your reply, we reserve the right to refuse the registration of your request.
You may, of course, use directly the electronic form for entering your request:
http://ec.europa.eu/transparency/regdoc/...
Best regards,
JUST ACCESS TO DOCUMENTS
Dear Justice and Consumers,
I have strong doubts that such a request is necessary or advisable.
Nevertheless, here is my address:
Paul-Olivier Dehaye
14 Rue de l'Abbaye
1196 Gland
Switzerland
Yours faithfully,
Paul-Olivier Dehaye
Dear Sir,
Thank you for your e-mails dated 11/02/2017 and 15/02/2017.
We hereby acknowledge receipt of your application for access to documents, which was registered on 15/02/2017 under reference number GestDem 2017/0950
In accordance with Regulation (EC) No 1049/2001 regarding public access to European Parliament, Council and Commission documents, your application will be handled within 15 working days. The time limit will expire on 09/03/2017. In case this time limit needs to be extended, you will be informed in due course.
Yours faithfully,
JUST ACCESS TO DOCUMENTS
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Dear Sir,
Please find a letter concerning your request for access to documents
GestDem No 2017/0950 attached.
With kind regards,
European Commission
DG Justice and Consumers
Unit JUST/C3 - Data Protection
1049 Brussels/Belgium