Ref. Ares(2022)3859679 - 23/05/2022
EUROPEAN COMMISSION
DIRECTORATE-GENERAL FOR TRANSLATION
The Director-General (acting)
Brussels
DGT/CE (2022)4053436
Alexander Fanta
netzpolitik.org
Schönhauser Allee 6-7
10119 Berlin
Germany
By registered mail with
acknowledgment of receipt
Advance copy by email:
ask+request-11108-
xxxxxxxx@xxxxxxxx.xxx
Subject:
Your application for access to documents
Ref.:
GestDem No 2022/2442
Dear Mr Fanta,
We refer to your message of 25 April 2022 in which you make a request for access to
documents, registered on 29 April 2022 under the above-mentioned reference number.
You request access to:
1.
Memos, guidance, guidelines, or training material (or any other document) for
staff on record creation and/or record keeping, especially on creation/keeping
of text messages.
2.
Memos, guidance, guidelines, or training material (or any other document) for
staff on the processing of access to information requests.
We have identified the following documents:
1.
Ares filing, DGT, 15/03/2021, Ares(2016)5506068 (hereafter ‘document 1’)
2.
Ares
which
emails
should
be
registered?,
DGT,
13/07/2021,
Ares(2016)5506068 (hereafter ‘document 2’)
Commission européenne, 2920 Luxembourg, LUXEMBOURG - Tel. +352 43011
Office: Ariane 03/C47 - Tel. direct line +352 4301-30271 - Fax +352 4301-30799
Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË - Tel. +32 22991111
Office: G--6 06/030 - Tel. direct line +32 229-88476 - Fax +32 229-30799
xxxxxxxx.xxxxxxxxx@xx.xxxxxx.xx
3.
Document lifecycle step by step, DGT, 19/11/2021 (hereafter ‘document 3’)
4.
Internal
-
Incoming
and
Outgoing
mail,
DGT,
10/03/2021
Ares(2016)5506068, (hereafter ‘document 4’)
5.
Glossary on administrative document management, DGT, 04/07/2012,
Ares(2016)5506068 (hereafter ‘document 5’)
6.
Explanatory notes and background file in Ares, DGT, 22/09/2016,
Ares(2016)5506068 (hereafter ‘document 6’)
With regard to documents 1, 2 and 6 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.
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 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.
Furthermore, with regard to document 2 listed above, some images have been blanked
out to protect intellectual property of a third party in accordance with Article 4(2), first
indent of Regulation (EC) No 1049/2001.
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
2
B-1049 Brussels, or by email t
o: xxxxxxxxxx@xx.xxxxxx.xx
Yours faithfully,
Christos ELLINIDES
Annexes:
6
3
Electronically signed on 20/05/2022 18:00 (UTC+02) in accordance with Article 11 of Commission Decision (EU) 2021/2121