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Electronic Access to European Commission Documents (EASE) Business Case
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TABLE OF CONTENTS
1 PROJECT INITIATION REQUEST INFORMATION ................................................................................. 5
2 CONTEXT ......................................................................................................................................... 6
2.1 Situation Description and Urgency ................................................................................................... 6
2.2 Situation Impact ................................................................................................................................ 7
2.3 Interrelations and Interdependencies ............................................................................................ 13
3 EXPECTED OUTCOMES ....................................................................................................................14
4 POSSIBLE ALTERNATIVES ................................................................................................................15
4.1 Alternative A: Do Nothing ............................................................................................................... 15
4.2 Alternative B: Using the Alaveteli solution ..................................................................................... 17
4.3 Alternative C: Using CASE@EC ........................................................................................................ 18
4.4 Alternative D: Develop a Building Blocks Based Solution ............................................................... 20
4.5 Conclusion ...................................................................................................................................... 20
5 SOLUTION DESCRIPTION .................................................................................................................22
5.1 Legal Basis ....................................................................................................................................... 22
5.2 Benefits ........................................................................................................................................... 22
5.3 Success Criteria ............................................................................................................................... 22
5.4 Scope .............................................................................................................................................. 23
5.5 Solution Impact ............................................................................................................................... 23
5.6 Deliverables .................................................................................................................................... 24
5.7 Assumptions ................................................................................................................................... 24
5.8 Constraints ...................................................................................................................................... 25
5.9 Risks ................................................................................................................................................ 25
5.10 Costs, Effort and Funding Source .................................................................................................... 26
5.11 Roadmap ......................................................................................................................................... 27
5.12 Synergies and Interdependencies ................................................................................................... 27
6 GOVERNANCE .................................................................................................................................28
6.1 Project Owner (PO) ......................................................................................................................... 28
6.2 Solution Provider (SP) ..................................................................................................................... 28
6.3 Approving Authority ....................................................................................................................... 28
APPENDIX 1: REFERENCES AND RELATED DOCUMENTS .........................................................................29
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2 CONTEXT
2.1 Situation Description and Urgency
The current landscape of tools supporting the submission and handling of applications to
access to Commission documents under Regulation 1049/2001 is fragmented and outdated.
There is very little automation as there are various channels for the submission of the
applications, consultation of the Member States and third parties and communication with the
applicants.
Moreover, the current system (GestDem) is cumbersome, not user-friendly enough and
sustained by a technology (ColdFusion) which will no longer be supported by DIGIT after the
end of 2020. Applicants have very limited possibilities to search and retrieve documents
already partially or fully disclosed under Regulation 1049/2001 as such documents are not fully
published. The applicants also do not have an overview or traceability of their requests while
the Member States have no overview of the documents on which they have been consulted.
On the side of Commission services who are responsible for replying to initial applications for
access, and the Secretariat-General, which is responsible for confirmatory applications1, the
current system does not provide an all-in-one case-management system. It does not provide
an overview of the workflow or the generation of the relevant statistics about the respect of
deadlines, the types of replies given and the types of documents released.
In order to analyse how to improve the business processes and the supporting IT tools for
submitting and handling requests for public access to documents, a comprehensive study was
conducted in 2018 in the context of the ISA² action 2018.05 ‘Electronic access to European
Commission documents - Study’. The outcomes of the study are:
1. ‘AS IS’ analysis [4] - The project team analysed the IT tools and business processes
currently in place (‘AS IS’) for handling applications for public access to documents,
from the submission of the applicant’s request up until the final answer of the
Commission.
2. Stakeholder consultations [8] - A wide range of consultations was carried out in 2018
in order to gather the stakeholders’ views and suggestions and assess the business
needs for the future IT system.
3. ‘TO BE’ analysis [5] - Based on the results of the consultations, the ‘TO BE’ business
process workflows were designed, covering both initial and confirmatory applications.
The overall processes cover the attribution and assessment of the requests for
documents, the third-party (including Member State) consultations, as well as the
dispatch of the reply to the applicant.
Moreover, during the study, we have explored solutions to provide applicants, Member States,
other EU institutions and third parties with a user-friendly interface to European Commission,
and to enable Commission services to deal with these stakeholders in an efficient and
coherent manner.
Volume of requests to be processed
Annually, the European Commission receives approximately 6000 initial applications and
around
300
confirmatory
applications
to
access
to
documents.
Of these requests, about 77% come through the online form, 23% come through other means
(e.g. paper, e-mail). The ‘AS IS’ analysis has revealed weaknesses of the current system: too
1 In case of a partial or full refusal of the access to the documents at the initial stage, the applicant can
file a confirmatory application in which the Secretariat-General conducts a fresh review of the case.
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many manual processes; a lack of tools to ensure that citizens' applications are dealt with in a
coherent and consistent manner.
Objective and urgency
The objective of the EASE (Electronic Access to European Commission Documents) project is to
ensure the Commission will be equipped with modern, electronic and integrated IT tools
allowing the submission and handling of the requests for public access to documents. The
solution will cover the public interface for communicating with applicants, the internal
workflows within the European Commission, and the consultations of other EU Institutions,
Member States and third parties, from the first request of the applicant to the final decision of
the Commission. The ultimate goal is to bring the EU decision-making process closer to its
citizens.
The urgency of the project is also justified by the fact that the current tools supporting the
public access to documents process are fragmented and are sustained by a technology
(ColdFusion) which will no longer be supported by DIGIT as from 2021.
Moreover, the current system, based on delivery by registered mail or by an express courier
service, has triggered criticism2 by the European Ombudsman and civil society, who consider it
cumbersome and not citizen-friendly enough. Therefore, the future ‘access to documents’
process needs to become more efficient and more user friendly for the citizen so as to make
the EU decision-making process more transparent in line with the Juncker Commission priority
of ‘Democratic Change’.
The aim of the future IT system is to be generic, reusable by any transnational, national or
subnational administration managing requests from the public for access to documents.
2.2 Situation Impact
2.2.1 Impact on Processes and the Organisation
The main objective of the project is to provide an information system that enables
streamlining of the access to European Commission documents processes across the different
stakeholders.
The future system will improve the workflows linked to the submission, processing and
preparation of replies to requests for access to European Commission documents. It also aims
to rationalise internal workflows and enhance consistency between replies.
2.2.1.1 Impacts on the organisation's strategy
The Commission services spend significant resources in processing requests to access to
documents. The current IT configuration provides limited support. Obtaining statistics and Key
Performance Indicators is difficult and incomplete due to the absence of any categorisation of
documents requested and released.
The new IT system will enable the Commission services to have a better overview of the types
of documents requested and released, and of the exceptions invoked. It will also ensure
increased coherence in the access granted to the same or similar documents requested at
different points in time, or by different Directorates-General or services.
The new system will also provide for the systematic identification of personal data dealt with
in the process of handing applications for access to documents, and their easy retrieval or
2 See decision in case 682/2014/JF
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deletion at a later stage. It will thereby ensure compliance with the requirement, laid down by
the new Data Protection Regulation 2018/1725, of ‘data protection by design’3.
2.2.1.2 Impacts on the IT landscape
The current landscape of tools supporting the public access to documents in possession of the
European Commission is fragmented and many exchanges are not electronic:
1. The European Commission provides, as part of the Register of Commission Documents
(‘RegDoc’), a web form allowing EU citizens and other beneficiaries to request access
to the documents in possession of the European Commission.
2. The NGO Access Info Europe, established in Madrid in 2006, provides a
separate/private website, AsktheEU, in which access to information and access to
document requests forwarded by e-mail to the European Commission are published.
This website uses the Alaveteli platform. Documents to which access is given under
Regulation 1049/2001, requests and the answers to the requests are made public on
that website. The main disadvantages are that:
a. the personal data contained in the communication between the European
Commission and the applicant are published automatically, and
b. the system does not generate acknowledgments of receipt of the answers and
the documents, which are critical to judge whether the confirmatory
application was submitted within the legal deadlines.
3. Today, applicants have no electronic means at their disposal to file confirmatory
applications (’appeals’ when an initial application is rejected or partially rejected).
4. Whereas consultations concerning documents originating from other institutions are
conducted via e-mail only, consultations of Member States and third-parties are not
fully electronic:
a. Consultations concerning documents originating from third parties are
conducted via registered mail / express courier delivery (an informal copy is
provided by e-mail);
b. Consultations concerning documents originating from Member States are
delivered by hand and by e-mail.
5. All written exchanges with applicants, Member States, third parties and other EU
institutions are manually encoded afterwards in a different information system, which
is called GestDem.
6. All (partially) negative initial replies are delivered by registered mail and by e-mail and
all confirmatory decisions are notified to applicants via DHL by the Secretariat-General
and by e-mail.
7. Notification/Consultation via registered mail or express courier delivery is required in
order to ensure the traceability of communication with the applicants, third parties
and Member States.
8. The Commission extracts statistics from GestDem, but these are incomplete, as the
system does not allow for a systematic encoding of the types of documents requested,
their subject matter, and the type of access granted. As a result, the Commission does
not have an overview of the types of documents to which access if most often
requested and the type of access that is generally granted to specific types of
documents.
3 The Commission’s Data protection Officer has proposed using the new system of a best practice
example in this respect.
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9. Because of the limited document categorisation and identification functionalities in
Ares/GestDem, it can happen that access to a document partially released in the past
is fully refused at a later stage, with negative consequences for the coherence of the
Commission’s policy, its image and its position in legal proceedings.
10. Units dealing with the treatment of initial and confirmatory applications for access to
documents have in some cases set up tailor-made delay monitoring systems. There is
no central overview of the respect of the deadlines under Regulation 1049/2001 at
initial and confirmatory level and the time taken for the successive steps in the
process;
11. If applicants asking for their personal data processed in the framework of the
treatment of an application for access to documents, the Commission has to search for
these data in various systems (email boxes, Ares/GestDem);
12. Templates and guidance on the use of the various exceptions and the Commission’s
administrative practice in this respect are available on MyIntracomm;
13. There is no corporate tool available to search previous decisions and documents
released according to words appearing in the text;
14. Adobe Acrobat Professional is currently used in order to redact selected parts of text
falling under one or several exceptions of Regulation 1049/2001;
15. The Commission’s electronic translation tools, developed by the Directorate-General
for Translation, are used case-by-case in order to understand the scope of applications
submitted in a language other than the languages mastered by the unit.
This project aims to eliminate this fragmentation and implement a fully electronic, holistic
solution for:
-
filing initial and confirmatory applications;
-
communicating with applicants throughout the application process;
-
consulting Member States, other EU institutions and third-parties;
-
replying to requests;
-
making documents released under Regulation 1049/2001 available to the wider public;
-
Identifying documents fully or partially released under Regulation 1049/2001 and
classifying them according to the document type and policy area concerned (e.g.
‘briefing’ related to ‘infringements’);
-
Identifying, extracting and deleting (after expiry of the retention period) personal data
processed when handling applications for access.
-
a corporate delay monitoring system enabling to monitor the respect of the deadlines
under Regulation 1049/2001;
-
integrating reply templates into the system for handling applications;
-
facilitating full-text search of previous decisions;
-
incorporating secure text redaction tools, with automatic full-text search capabilities
for specific types of data (e.g. names; Member States’ acronyms);
-
incorporating automatic text translation tools in order to enable a first assessment to
be made of the scope (e.g. falling under Regulation 1049/2001 or not) of new
applications..
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In order to handle applications for public access to European Commission documents,
Commission staff needs to exchange information with applicants, Directorates-General,
Member States and other third parties.
3 EXPECTED OUTCOMES
The main objective of the EASE project is to implement a one-stop-shop for submitting and
handling the applications for access to Commission documents under Regulation 1049/2001. .
It is designed to tackle the issues outlined in the analysis of the surveys conducted amongst
Commission staff, the general public (including applicants), Member States and the unit in the
European Parliament dealing with access to documents.
The solution aims to provide the Commission with an end-to-end electronic system that
supports the business process for handling initial and confirmatory applications, including
better delay monitoring and more informative statistics.
The system will provide applicants with a streamlined interface, more transparency through
e.g. status updates and more powerful tools for searching and accessing exiting documents,
including those disclosed in previous applications for access to documents.
Public administrations and European institutions will be able to make use of the functionalities
developed for the new information system for their secure electronic exchange of information
with the Commission, other institutions and Member States, thereby facilitating cooperation
and reducing handling times.
The solution will leverage synergies with existing and future corporate solutions like
Hermes/Ares/Nomcom (HAN), the public Register of Commission Documents, EULogin,
eSignature, eSeal, eConfidentiality, Poetry, Secunda/MAUS.
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The paper-based communication of replies
(by registered mail and express courier
service) has been criticised by the
European Ombudsman and civil society,
affecting negatively the Commission’s
pursued image as a ‘modern’ and
‘transparent’ administration.
4.1.3 Qualitative Assessment
This alternative would maintain the current status quo, with the severe limitations in term of
transparency, quality and high workload for all users.
This alternative provides a limited set of features for all users. It supports a limited subset of
the requested features. Notably, it does not cover the confirmatory request workflow and has
limited support for the internal workflows in the Commission.
DIGIT will cease support to ColdFusion in 2021.
Factoring in all considerations, we conclude that this is
not a viable alternative.
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Trained resources pose a retention risk
due to financial constraints and market
demand.
4.3.3 Qualitative Assessment
This tool is a corporate case management product initiated by DG COMP. The purpose of this
product is to evolve in the coming years to become a standard tool for the Directorates-
General.
The tool uses a fee-based approach and an inherent dependence on IBM’s pricing and
assistance policy.
A solution based on CASE@EC could cover an important part of the workflows employed by
the European Commission. The features used by applicants or by other external stakeholders
require complementary implementations.
CASE@EC team aims to deliver to production in 2022, giving priority to Directorates-General
members of the Inter-service Working Group6. This approach, coupled with the specific skillset
required to deliver a solution, implies a realistic delivery for Unit SG.C.1 – Transparency,
Document Management & Access to Documents around 2022. This schedule is not in line with
the time constraints of the EASE project to be delivered partially in 2019 and in full in 2020.
The primary weakness of CASE@EC is its incompatibility with the business processes used in
the handling of applications to access to documents. The handling of such applications requires
a workflow based on well-defined and pre-established steps. In contrast, CASE@EC is case-
based.
Taking into account all above factors, we conclude that
CASE@EC is not a viable alternative.
6 Inter-service Working Group is composed of: DG COMP (chair), OLAF, DG AGRI, DG MARE, DG TRADE,
DG BUDGET
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5 SOLUTION DESCRIPTION
5.1 Legal Basis
Article 15(3) TFEU,
Regulation 1049/2001,
Regulation 1367/2006,
Regulation 1725/2018,
Commission Decision 2001/937/EC.
5.2 Benefits
The following benefits have been identified:
The solution will offer a new set of features, such as workflow management with
regard to initial and confirmatory requests and data protection by design. It will
improve existing workflows (e.g. search facilities, interactions with third parties and
applicants, elaboration of informative statistics). It will help the Commission to
increase its productivity (do more with same amount of resources).
Implementing features requested by stakeholders such as search and retrieval of
previous replies and previously released documents, automated communications via
templates, would contribute to reducing the response times.
Enhanced feedback to applicants and easier access to already available documents
would lead to enhanced transparency.
Improved reporting and feedback to users will help increase the quality of service.
Business-driven built-in reporting capabilities for key indicators will facilitate the
monitoring of the quality of replies and the respect of the legal deadlines.
Implementing an end-to-end electronic workflow will decrease operational expenses
(e.g. postage) Using state-of the art technologies will also contribute to lowering
system maintenance costs, and reinforce the Commission’s image as a modern and
transparent public administration.
The proposed solution seeks to leverage synergies with corporate solutions. We have
identified potential interactions with ARES and public registers of Commission
documents)
5.3 Success Criteria
The project will be considered a success if the IT solution will cover the ‘TO-BE’ workflows in an
efficient manner. Success criteria are defined for the project, independent on the selected
solution. The Project Steering Committee will use following Key Performance Indicators to
measure its success:
Wide uptake and positive evaluation of the new IT system by Commission staff (75 %
satisfied or very satisfied);
Wide uptake by citizens of the new means of communicating with Commission
services on applications for access, resulting in only 5% of requests lodged by non-
electronic means;
20 % reduction in the time needed for the administrative handling of applications for
access;
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5.11 Roadmap
This project will follow agile principles for building the IT solution. Agile sprints will be of 2-4
weeks.
Initiating Phase:
Definition of the context, impact and outcomes of the envisaged solution
2018
Business Case approved
Q1 2019
Project Charter approved by the Information Technology and
April 2019
Cybersecurity Board
Planning Phase:
Project planning artefacts approved
April 2019
Security Plan
2020
Executing Phase:
Request for new Website to DG COMM
June 2019
Architecture Overview
June 2019
Public Portal and Requests Management system (Version 1)
Q4 2019
Public Portal and Requests Management system (Version 2)
Q4 2020
Closing Phase:
Project completed
Q4 2020
5.12 Synergies and Interdependencies
The Project Support Team has identified an array of components for the proposed solution:
The system will use
HAN to reference relevant documents
EU Login facilitate users' access to a wide range of Commission information systems
Compass Corporate provides multiple features e.g. workflow engine, document
management
EU Send will help the system with secure data delivery in order to integrate with other
stakeholders’ systems
eSignature/eSeal provide mechanisms for creating and verifying electronic signatures
eTranslation provides machine translation capabilities to help stakeholders exchange
information across language barriers
Secunda/
EU Access provides user authorisation management
Corporate Search for the search of documents
The landscape of corporate solutions is evolving continuously. Thus, Project Support Team will
monitor for relevant components and propose them to the Project Steering Committee as they
become available.
The solutions developed in this project will be shared with other Directorates-General
or
external stakeholders that may be interested in extending the system with new features or in
integrating components in their own workflows.
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6 GOVERNANCE
6.1 Project Owner (PO)
The Project Owner is
,
SG.C.1 - Transparency, Document
Management & Access to Documents.
6.2 Solution Provider (SP)
The Solution Provider is
,
SG.C.5 - Digital Solutions & Process
Efficiency.
6.3 Approving Authority
The Approving Authority is the IT and Cybersecurity Board.
Signature of the approving authority …………………………… Date …………………………
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