DIRECTORATE-GENERAL FOR FINANCIAL STABILITY, FINANCIAL SERVICES AND CAPITAL
Head of Unit
FISMA B2 HH/az/2020
Mr Kenneth Haar
Overgaden oven Vandet 12
1415 Copenhagen K
Denmark By registered letter with
acknowledgement of receipt
Advanced copy per e-mail
Subject: Your request for access to documents (our ref. GESTDEM: 5072/2020)
Dear Mr Haar,
Thank you very much for your e-mail dated 15 July 2020, in which you make a request
for access to documents, registered under the above mentioned reference number.
Your request is as follows:
“Under the right of access to documents in the EU treaties, as developed in Regulation
1049/2001, I am requesting documents which contain the following information:
1) a list of meetings that address delegated acts to implement the taxonomy regulation
(from 1. January 2020 till present day) of Commissioner Dombrovskis a n d memb ers o f
her cabinet or representatives of DG FISMA AND representatives of industry groups
from the financial sector or the energy sector (production and distribution).
2) minutes and other reports of these meetings;
3) all correspondence with entities listed above on the taxonomy regulation, including
emails from 1. January 2020 till present day).”
As regards your request concerning meetings and written communications for Executive
Vice-President Dombrovskis and his Cabinet, all relevant documents have been added to
your request. After a search, we could identify 46 documents which are enclosed in the
list of documents.
Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË - Tel. +32 22991111
Office: SPA2 09/044 ‐
Having examined the documents requested under the provisions of Regulation (EC)
No 1049/2001 regarding public access to documents, I have come to the conclusion that
they may be only partially disclosed as they contain personal data, in particular names
and contact details. Therefore, some parts of the documents have been blanked out and
their disclosure is prevented by exception to the right of access laid down in Article 4 of
this Regulation, for data protection reasons.
Personal data can only be transmitted under specific exceptional conditions, including if ‘the recipient establishes that it is necessary to have the data transmitted f or a specific
purpose in the public interest.
According to Article 9(1)(b) of Regulation 2018/1725, the
European Commission also only has to examine the further conditions for a lawful
processing of personal data if the recipient has established that it is necessary to have the
data transmitted for a specific purpose in the public interest. 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.
Notwithstanding the above, please note that there are reasons to assume that the
legitimate interests of the data subjects concerned would be prejudiced by disclosure of
the personal data reflected in the documents.
Consequently, I conclude that, pursuant to Article 4(1)(b) of Regulation 1049/2001,
access cannot be granted to the personal data, 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.
Should you disagree with the assessment that the redacted data are personal data which
can only be disclosed if such disclosure is legitimate under the applicable rules on the
protection of personal data, you are entitled, in accordance with Article 7(2) of
Regulation 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
Unit C.1. ‘Transparency, Document Management and Access to Documents’
B-1049 Bruxelles, or by email to: email@example.com
Enclosures: List of documents and 46 documents redacted