ccess to documents – Media payments through Havas framework contract

Marit Nubé made this access to documents request to Budget Automatic anti-spam measures are in place for this older request. Please let us know if a further response is expected or if you are having trouble responding.

Budget has replied saying you have to contact another public body.

Dear Budget,

I am a journalist working for an independent Dutch media platform. In this capacity, I request access to the following documents under Regulation (EC) No 1049/2001 regarding public access to European Parliament, Council and Commission documents:
1. All documents relating to the framework contract(s) between the European Commission and Havas Media France concerning the distribution of media funding in the period 2020–2025.
2. A list of media outlets or organizations that received funding, grants, or promotional contracts via Havas Media under this framework.
3. The specific selection criteria and budgetary breakdown of funds allocated via this mechanism, particularly in the context of the 2024 European Parliament election period.
4. Any communication, minutes or emails exchanged between the European Commission and Havas Media France or Vivendi concerning editorial independence, distribution of funds, or public transparency.

If parts of these documents are confidential or redacted, I kindly ask for partial disclosure under Article 4 of the Regulation.

I am happy to clarify or refine this request further if needed.

Sincerely,
Marit Nubé
Journalist – NieuwRechts

BUDG-ACCES-DOCUMENTS@ec.europa.eu,

Dear Sir or Madam,

We are writing to you concerning your request for access to documents sent
on 11/04/2025 and registered on 11/04/2025 under case number 2025/2065.

Since you have not indicated your postal address, we are not able to start
handling your request. The 15 working days to reply to your request will
start running only when you send us your postal address.

You can send your postal address by replying to this e-mail. If we do not
receive your reply we may close this case.

Please note that you can submit a request for access to Commission
documents via the portal [1]'Request a Commission document', which does
not require you to indicate your postal address.

Why do we need your personal postal address?

Since 1 April 2014, the submission of a postal address became a mandatory
feature when submitting an application for access to Commission documents
via an e-mail. We would like to explain why we need your postal address in
order to register and handle your application for access to documents when
submitted via e-mail:

• Firstly, to obtain legal certainty as regards the date you received
the European Commission reply to your application for public access to
documents. Article 297 of the Treaty on the Functioning of the
European Union (TFEU) states that 'decisions which specify to whom
they are addressed, shall be notified to those to whom they are
addressed and shall take effect upon such notification.' In line with
this provision, if the Commission does not grant full access to the
requested documents, it notifies the reply to the applicant via
registered mail with acknowledgement of receipt or via delivery
service. This requires an indication of a valid postal address by the
applicant;
• Secondly, to apply correctly the [2]Data Protection Regulation (EU)
2018/1725. Knowing whether the applicant is an EU resident (or not) is
necessary for deciding which conditions shall apply for the
transmissions of personal data to applicants for access to documents.
These conditions are not the same for recipients established in the
Union and for recipients in third countries. As the vast majority of
the documents requested contain personal data, the Commission cannot
ensure the correct application of the data protection rules in the
absence of a postal address;
• Thirdly, to apply correctly [3]Regulation (EC) No 1049/2001. Article
4(1)(b) of that Regulation refers to the protection of the privacy and
integrity of the individual and has to be applied in line with the
Data Protection Regulation;
• Fourthly, to protect the interest of other citizens and safeguard the
principle of good administration. The Commission has to treat all
citizens equally by ensuring that the legal framework for public
access to documents is respected. For example, it has to verify
whether Article 6(3) of Regulation (EC) No 1049/2001 is being evaded
by introducing several requests under different identities. Indeed, in
its Ryanair judgment ([4]EU:T:2010:511), the General Court confirmed
that Article 6(3) of Regulation (EC) No 1049/2001 cannot be evaded by
splitting an application into several, seemingly separate, parts. In
addition, the Commission has to make sure that the legal framework is
respected and the right of access to documents is not abused by making
requests under an invented identity.

The considerations above show that the request for and the consequent
processing of the applicant's postal address is not only appropriate, but
also strictly necessary for the performance of a task carried out in the
public interest within the meaning of Article 5(1)(a) of Data Protection
Regulation, namely providing a smooth and effective access to documents.

Yours faithfully,

Directorate-General for Budget - Access to Documents
European Commission

References

Visible links
1. https://www.ec.europa.eu/transparency/do...
2. https://eur-lex.europa.eu/legal-content/...
3. https://eur-lex.europa.eu/legal-content/...
4. https://eur-lex.europa.eu/legal-content/...

Dear Budget,

Thank you for your message. My postal address is as follows:
[Name] Cvandaag
[Street] Arthur van Schendelstraat 650
[ZIP Code] 3511 MJ Utrecht

Yours faithfully,

Marit Nubé

BUDG-ACCES-DOCUMENTS@ec.europa.eu,

Dear Sir or Madam,

We hereby acknowledge the receipt of your request for access to documents
sent on 11/04/2025 and registered on 15/04/2025 under the case number
2025/2065.

We will handle your request within 15 working days as of the date of
registration. The time-limit expires on 13/05/2025. We will let you know
if we need to extend this time limit for additional 15 working days.

To find more information on how we process your personal data, please see
[1]the privacy statement.

Yours faithfully,

Directorate-General for Budget - Access to Documents
European Commission

References

Visible links
1. https://ec.europa.eu/info/principles-and...

COMM-ACCES-DOCUMENTS@ec.europa.eu,

Dear Sir,

You have sent requests for access to documents regarding Media payments
through Havas framework contract to the European Commission “Secretariat
General” and “Budget” on 11/04/2025. Those requests were registered on
11/04/2025 and on 15/04/2025 under the case numbers 2025/2060 and
2025/2065, respectively.  

Please be informed that your initial requests for access to documents
regarding Media payments through Havas framework contract will be dealt
with by the European Commission, Directorate-General for Communication.

As the request registered under the case number 2025/2065 is a duplicate
of the request 2025/2060, we will therefore close the reference 2024/2065
in our database and you will receive a reply to your request registered
under the case number 2025/2060.

Kind regards,

Access to documents team

DG COMM