Ref. Ares(2023)554218 - 25/01/2023
EUROPEAN COMMISSION
DIRECTORATE-GENERAL
ENVIRONMENT
Directorate B – Circular Economy
ENV.B.2 – Safe & Sustainable Chemicals
Mr. Olivier Petitjean
2 impasse Delaunay
F-75011 Paris
France
Sent by e-mail: xxxxxxxxxxxxxxxxxxxxxxxxxx@xxxxxxxx.xxx
Dear Mr. Petitjean,
Subject:
Your application for access to documents – EASE 2022/4700
We refer to your e-mail of 18 August 2022 in which you make a request for access to
documents, registered under the above mentioned reference number, and to our holding
reply Ares(2022)6240213. We would like to sincerely apologise for the delay in our
reply.
You requested access to: “
… All documentation (including but not limited to all email
correspondence, attendance lists, agendas, background papers, transcripts, recordings
and minutes/notes) relating to the meetings listed below:
1. Between Elena Montani and Dow Europe, on 13th July, 2022
2. Between Carmen Preising and BDI on 6th July, 2022”.
Your application concerns the following documents:
- Ares(2022)8282309 - Minutes meeting with DOW, 13 July 2022;
- Ares(2022)8282166 - Flash report meeting with BDI – Commissioner Sinkevičius, 6
July 2022.
With regard to 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 of Commission staff members not pertaining to the Cabinets or to
senior management;
- the names of other 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
Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË - Tel. +32 22991111
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.
These documents were drawn up for internal use under the responsibility of the relevant
officials. They solely reflect the authors’ interpretation of the interventions made and do
not set out any official position of the third parties to which the documents refer, which
were not consulted on their contents. 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 to the Secretariat-General of the
Commission within 15 working days upon receipt of this letter. You can submit it in one
of the following ways:
by asking for a review via your portal1 account (available only for initial requests
submitted via the portal account),
or by mail:
European Commission
Secretariat-General
Transparency,
Document
Management
&
Access
to
Documents
(SG.C.1)
BERL 7/076
B-1049 Bruxelles
or by email to: xxxxxxxxxx@xx.xxxxxx.xx
Yours faithfully,
(E-signed)
Cristina de Avila
Head of Unit
1
https://www.ec.europa.eu/transparency/documents-request
2
Electronically signed on 24/01/2023 19:04 (UTC+01) in accordance with Article 11 of Commission Decision (EU) 2021/2121