Ref. Ares(2022)6280802 - 12/09/2022
EUROPEAN COMMISSION
SECRETARIAT-GENERAL
Directorate D - Twin Transition, Economic & Social Affairs
SG.D.1 - Digital Transition, Industry & Single Market
Brussels
SG.D.1
Nienke Palstra
Global Witness
Rue Belliard 53
1000, Bruxelles
Belgium
E-mail: ask+request-11718-
xxxxxxxx@xxxxxxxx.xxx
Dear Ms Palstra,
Subject:
Your application for access to documents – GESTDEM 2022/4585
We refer to your e-mail sent on 11 August 2022 and registered on 12 August 2022 in which you
make a request for access to documents, under the above mentioned reference number.
You requested access to “
[a]ll documents—including but not limited to correspondence, emails,
minutes, notes (hand written or electronic), audio or video recordings, verbatim reports,
operational conclusions, lines to take, briefings, and presentations—related to the meeting on 2022-
06-15 between Despina Spanou and Bitkom e.V..”
The following documents fall within the scope of your application:
Flash report - Meeting with Bitkom 15.06.2022
With regard to the document listed above, a complete disclosure of the identified 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 they contain the following
personal data:
-
the names/initials and contact information of Commission staff members not pertaining to the
senior management;
-
the names/initials and contact details of other natural persons;
Article 9(1)(b) of the Data Protection Regulation (Regulation 2018/1725) 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.
The document was drawn up for internal use under the responsibility of the relevant officials of the
European Commission. It solely reflects the author's interpretation of the interventions made and
does not set out any official position of the third parties to which the document refers. It does not
reflect the position of the Commission and cannot be quoted as such.
In accordance with Article 7(2) of Regulation (EC) No 1049/2001, you are entitled to make 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 Secretary-General of the Commission at the following address:
European Commission
Secretariat-General
Transparency, Document Management & Access to Documents (SG.C.1)
BERL 7/076
B-1049 Brussels
or by email to:
xxxxxxxxxx@xx.xxxxxx.xx
Please kindly send an acknowledgement of the receipt of this reply.
Yours faithfully,
(e-signed)
Elisa Roller
Director
Annex:
1 document
2
Electronically signed on 12/09/2022 06:39 (UTC+02) in accordance with Article 11 of Commission Decision (EU) 2021/2121