Ref. Ares(2020)4433412 - 26/08/2020
EUROPEAN COMMISSION
DIRECTORATE-GENERAL FOR INTERNAL MARKET, INDUSTRY, ENTREPRENEURSHIP
AND SMES
Chemicals and Consumer Industries
The Director
Brussels
GROW.D.2/AS
GROW.DDG1.D.2(2020)5042223
Vicky Cann
Corporate Europe Observatory
Per email only to:
ask+request-8371-
xxxxxxxx@xxxxxxxx.xxx
Subject:
Reply to your access to document request Gestdem 2020/4358
Dear Madam,
We refer to your e-mail of 16 July 2020 in which you make a request for access to documents,
registered on 16 July 2020 under the above-mentioned reference number.
You request access to “a list of all lobby meetings (including face to face, phone calls, conference
calls etc) held since 29 January 2020 where the Chemicals Strategy for Sustainability was
discussed. The list should include the names of the individuals and organisations participating;
the date; the agenda; and any minutes / notes produced. I would additionally like to receive any
emails or other correspondence from lobby groups related to the Chemicals Strategy for
Sustainability received or sent since 29 January 2020.
Please provide all responses electronically via this site.
”
I consider your request to cover documents held up to the date of your initial application,
i.e. 16 July 2020.
Your application concerns the 13 documents and their attachments listed in Annex.
With regard to all the documents
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;
-
handwritten signatures/abbreviated signatures of natural persons.
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 express any particular
Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË - Tel. +32 22991111
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.
Please note that documents 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.
Minutes/summary records were drawn up for internal use under the responsibility of the relevant
services of the Directorate-General for GROW. It solely reflects the services’ interpretation of the
interventions made and does not set out any official position of the third parties to which the
document refers, which was not consulted on its content. It does 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:
European Commission
Secretariat-General
Unit C.1. ‘Transparency, Document Management and Access to Documents’
BERL 7/076
B-1049 Brussels, or by email to:
xxxxxxxxxx@xx.xxxxxx.xx
Yours faithfully,
(e-signed)
Carlo PETTINELLI
2
Electronically signed on 26/08/2020 12:17 (UTC+02) in accordance with article 4.2 (Validity of electronic documents) of Commission Decision 2004/563