Ref. Ares(2020)2292571 - 29/04/2020
DIRECTORATE-GENERAL FOR EDUCATION, YOUTH, SPORT AND CULTURE
Performance Management, Supervision and Resources
Organisational Performance and Legal Affairs
Dear Ms. Spearing,
Your application for access to documents – Ref GestDem 2020/1745
We refer to your e-mail dated 3/03/2020 in which you make a request for access to documents,
the part of your request concerning our competencies was registered on 27/03/2020 with the
reference number GestDem 2020/1745.
Your request was the following: any meeting agendas, minutes or relevant documents on the
policy dialogues between the EU and China between 2009 and 2020 on the “III Pillar - People-to-
We are pleased to provide you with 27 documents, which are annexed to this letter. You will also
find a summary table with the list of the documents.
With regard to the documents 2 to 27, 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 Regulation1 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, as the need to obtain access thereto for a purpose in the public
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.
Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË - Tel. +32 22991111
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 documents listed in a table attached, were drawn up under the responsibility of the relevant
services of the Directorate-General for Education and Culture and of the Directorate-General for
Employment, Social Affairs and Inclusion. They solely reflect the services’ interpretation of the
interventions made and do not set out any official position of the third parties to which the
document refers, who 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:
Unit C.1. ‘Transparency, Document Management and Access to Documents’
B-1049 Bruxelles, or by email to: firstname.lastname@example.org
Head of Unit
Electronically signed on 29/04/2020 09:55 (UTC+02) in accordance with article 4.2 (Validity of electronic documents) of Commission Decision 2004/563