Ref. Ares(2021)6483363 - 21/10/2021
EUROPEAN COMMISSION
DIRECTORATE-GENERAL JUSTICE AND CONSUMERS
Unit 01: Communication and strategic planning
Brussels,
just.01.002(2021)7243028
Ms Naomie HIRST
Global Witness
Rue Belliard 53
1000 Brussels
Belgium
By e-mail:
ask+request-10028-
xxxxxxxx@xxxxxxxx.xxx
Subject:
Your application for access to documents – GESTDEM 2021/5988
Dear Ms Hirst,
We refer to your e-mail of 08/10/2021 in which you make a request for access to
documents, registered on 11/10/2021 under the above mentioned reference number.
You request access to:
“All documents—including but not limited to correspondence, emails, minutes, notes
(hand written or electronic), audio or video recordings, verbatim reports, operational
conclusions, lines to take, briefings and presentations—related to the meeting on 2021-
07-12 between Wojtek Talko, Monika Ladmanova and Daniel Braun and Facebook
Ireland Limited”.
Your application concerns the following document:
- Flash report: Meeting on Political Ads between Cabinet Jourova members and
Facebook representatives 12/07/2021 (reference number Ares(2021)5471702).
A complete disclosure of the identified document 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.
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
Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË
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.
This document was drawn up for internal use under the responsibility of the relevant
services. 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
Transparency, Document Management & Access to Documents (SG.C.1)
BERL 7/076
B-1049 Bruxelles
or by email to:
xxxxxxxxxx@xx.xxxxxx.xx
According to standard operational procedure, the reply to a request for access to documents
is usually sent by registered post. Please note, however, that due to the extraordinary health
and security measures currently in force during the COVID-19 pandemic, which include the
requirement for all Commission non-critical staff to telework, we are unfortunately not in a
position to follow this procedure until further notice.
We would therefore appreciate if you could confirm receipt of the present e-mail by
replying to
xxxxxxxxxxxxxxxxxxxx@xx.xxxxxx.xx. Yours faithfully,
Giles GOODALL
Head of Unit
(e-signed)
2
Electronically signed on 21/10/2021 14:11 (UTC+02) in accordance with article 11 of Commission Decision C(2020) 4482