
Ref. Ares(2022)1222377 - 18/02/2022
EUROPEAN COMMISSION
DIRECTORATE-GENERAL
ENVIRONMENT
The Director-General
Brussels,
ENV/B.2
Marie Milet
1 Long Lane
London
United Kingdom
SE1 4PG
Sent by email with acknowledgement of
receipt:
xxxxxxxxxxxxxxxxxxxxxxxxxx@xxxxxxxx.xxx
Dear Ms Milet
Subject:
Your application for access to documents – Ref GestDem No 2021-8036
We refer to your e-mail dated 1 December 2021 in which you make a request for access to
documents, registered under the above-mentioned reference number. We would like to sincerely
apologise for the delay in our reply.
You requested access to: “
documents which contain the following information:
All documentation, including but not limited to attendance lists, agendas, background papers,
minutes/notes and email correspondence about or summarising, the following:
Meeting titled “To share views on Chemicals Strategy and the roadmap of Circular Economy
Action Plan” with representatives of the Environment, Oceans and Fisheries, Commissioner
Virginijus Sinkevičius, and Camilla Bursi, Cabinet member of Virginijus Sinkevičius on
10/06/2020”.
With regard to your request, please see enclosed copies of the following 4 documents identified as
falling within its scope:
1. Cefic email of 10 December 2019;
2. Cefic letter of 6 December 2019 requesting a meeting, attached to the email of 10 December
2019;
3. Email of 26 February 2020 from Cabinet of Commissioner Sinkevičius, with positive reply
to the request for a meeting;
4. Summary record of the Webex meeting of 10 June 2020 between Commissioner Sinkevičius
and CEFIC.
Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË - Tel. +32 22991111
Having examined these documents under the provisions of Regulation (EC) No 1049/2001
regarding public access to European Parliament, Council and Commission documents, we have
come to the conclusion that complete disclosure 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, which have been redacted:
-
Specific contact details (office numbers and phone numbers) of Cabinet staff members;
-
Names, contact details, and handwritten signatures of other natural persons.
In your application, you indicate that your address is in the United Kingdom. Transfers of personal
data from the Commission to countries that are not members of the European Economic Area
(EEA), or to international organisations, are regulated under Chapter V of the Data Protection
Regulation1.
According to Article 47(1) of this Regulation, a transfer of personal data to a third country or an
international organisation may take place where the Commission has decided that the third country,
a territory or one or more specified sectors within that country, or the international organisation in
question, ensures an adequate level of protection and where the personal data are transferred solely
to allow tasks within the competence of the controller to be carried out.
Based on the information available, the country of your residence is recognised by the Commission
as ensuring an adequate level of protection. However, we would further like to inform you that
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 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 that have been redacted in the identified 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.
Please also note the following:
- The enclosed summary record of the meeting was drawn up for internal use under the
responsibility of the relevant officials of the Directorate-General for Environment. It solely reflects
the authors’ interpretation of the interventions made and does not set out any official position of the
third parties to which the document refers, which were not consulted on its content. It does not
reflect the position of the Commission and cannot be quoted as such.
- The email and letter originating from a third party are disclosed to you based on Regulation (EC)
No 1049/2001 and the third party was consulted on their disclosure. However, this disclosure is
without prejudice to the rules on intellectual property, which may limit your right to reproduce or
1 Regulation (EU) 2018/1725 of the European Parliament and of the Council of 23 October 2018 on the protection of
natural persons with regard to the processing of personal data by the Union institutions, bodies, offices and agencies
and on the free movement of such data, and repealing Regulation (EC) No 45/2001 and Decision No 1247/2002/EC,
OJ L 295, 21.11.2018, p. 39.
exploit the released documents without the agreement of the originator, who may hold an
intellectual property right on them. The European Commission does not assume any responsibility
from their reuse.
In accordance with Article 7(2) of Regulation 1049/2001, you are entitled to make a confirmatory
application requesting the Commission to review its position on the matters already mentioned.
Such a confirmatory application should be addressed within 15 working days upon receipt of this
letter to the Secretary-General of the Commission at the following address:
European Commission
Secretary-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 sincerely,
e-signed
Florika FINK‑HOOIJER
Electronically signed on 17/02/2022 17:31 (UTC+01) in accordance with article 11 of Commission Decision C(2020) 4482