ECB-UNRESTRICTED
DIRECTORATE GENERAL SECRETARIAT
Peter Teffer
Follow the Money
Overtoom 197
1054 HT Amsterdam
The Netherlands
xxxxxxxxxxxxxxxxxxxxxxxxxx@xxxxxxxx.xxx
1 June 2022
Reference: LS/PS/2022/28
Request for public access to ECB documents
Dear Mr Teffer,
On 6 May 2022 the European Central Bank (ECB) received your application for public access to
‘[a]ll
documents discussing the possible participation of the European Central Bank in an independent EU
ethics body, including but not limited to all letters to the European Commission on this issue”.
1. Identification of the requested documents
After having carefully examined your request in accordance with
Decision ECB/2004/3, the ECB has
identified six ECB documents of relevance to your application, namely an internal memo to the
Executive Board on “Establishment of an EU Ethics Body – consultation from the European
Commission”, including four annexes, and a letter dated 2 May 2022 from ECB President Lagarde to
European Commission President von der Leyen confirming the ECB’s interest in participating in the
interinstitutional discussions on a possible future joint agreement to establish an independent EU
ethics body. A comprehensive list of those documents is provided in the Annex to this letter.
2. Assessment of the requested documents for disclosure
Following a thorough assessment in accordance with the requirements set out in Decision ECB/2004/3,
and in consultation with the European Commission, as applicable, we are pleased to inform you that
the ECB has decided that access can be granted to all documents since none of the exceptions listed
1
ECB-UNRESTRICTED
in Article 4 of that Decision apply. In addition, document 2 is publicly available on the website of the
European Parliament.
3. Protection of personal data
Where applicable, parts containing personal data of staff members of the ECB or of third parties
(namely, names of staff members, signatures, handwritten salutations) have been redacted, together
with any non-public information that would make the data subjects identifiable. Personal data are
protected by Article 4.1(b) of Decision ECB/2004/3 in conjunction with Article 9 of Regulation (EU)
2018/1725 of the European Parliament and of the Council. Article 9(1)(b) of Regulation (EU) 2018/1725
stipulates that, for the transfer of personal data, the recipient must establish a necessity to have
personal data transmitted for a specific purpose in the public interest. Since you have not established
such a necessity, access to personal data in the documents must be refused on the basis of Article
4(1)(b) of Decision ECB/2004/3.
4. Final remarks
The documents are now available in the ECB’s
Public Register of Documents (see links in the
Annex).
For the sake of good order, we would like to inform you that, in line with Article 10 of Decision
ECB/2004/3, “Documents released in accordance with this Decision shall not be reproduced or
exploited for commercial purposes without the ECB’s prior specific authorisation. The ECB may
withhold such authorisation without stating reasons.”
Yours sincerely,
[signed]
[signed]
Petra Senkovic Margarita-Louiza Karydi
Director General Secretariat Head of the Compliance and Governance Division
Annex
2
ANNEX
ECB-UNRESTRICTED
Number Description of ECB document
Disclosure
∗ subject to redaction
of personal data
Yes*
1
ECB staff memo dated 4 April 2022 to the Executive Board on “Establishment
of an EU Ethics Body – consultation from the European Commission”
link
2
Annex 1 - European Parliament Resolution of 16 September 2021 on
published
strengthening transparency and integrity in the EU institutions by setting up
an independent EU ethics body (2020/2133(INI))
Yes
3
Annex 2 - Note of the European Commission: Follow-up to the European
Parliament non-legislative resolution on strengthening transparency and
link
integrity in the EU institutions by setting up an independent EU ethics body
Yes*
4
Annex 3 - Consultation letter dated 18 March 2022 from President von der
Leyen to President Lagarde, on participation in interinstitutional discussions
link
on a possible future joint agreement to establish an ethics body common to
all EU institutions, the European Economic and Social Committee and the
Committee of Regions
Yes
5
Annex 4 - Summary of main European Parliament and European
Commission views
link
Yes
6
Letter dated 2 May 2022 from President Lagarde to President von der Leyen,
confirming the ECB’s interest in participating in the interinstitutional
link
discussions on a possible future joint agreement to establish an ethics body
common to all EU institutions, the European Economic and Social Committee
and the Committee of Regions.
3