Ref. Ares(2023)4536695 - 30/06/2023
EUROPEAN COMMISSION
DIRECTORATE-GENERAL FOR FINANCIAL STABILITY, FINANCIAL SERVICES AND CAPITAL
MARKETS UNION
General Affairs
Policy planning and implementation, inter-institutional relations
Brussels,
Mr Maximilian HENNING
e-mail:
ask+request-13161-
xxxxxxxx@xxxxxxxx.xxx
Subject:
Your application for access to documents – EASE 2023/3440
Dear Mr Henning,
We refer to your request for access to European Commission documents registered on
16 June 2023 under the above-mentioned reference number.
You requested:
All minutes, agendas, summaries, notes or memos issued before or after; documents
prepared for, issued in preparation for, or exchanged during; as well as all
correspondence including attachments by either of the meeting parties related to
27.04.2023 meeting between Asociación Española de Banca, Banco Santander, S.A.,
BANCO BILBAO VIZCAYA ARGENTARIA and Cabinet members of Commissioner
McGuiness.
We have identified two documents that fall in the scope of your request:
1. ARES(2023)3185338 - Meeting request;
2. ARES(2023)3185416 – Minutes of the meeting.
The document number 1 originates from third parties. The originators of the document
have been consulted in accordance with Article 4(4) of Regulation 1049/2001 with a view
to assessing whether an exception provided for in Article 4 of that Regulation is applicable.
They agree to disclose the document with redaction of personal data and any other
information that can allow the identification of data subjects.
Furthermore, please consider that the minutes identified as document number 2 were drawn
up for internal use under the responsibility of the relevant member of staff. The minutes
solely reflect the author’s interpretation of the interventions made and do not set out any
official position of the third parties, to which the documents refer, who were not consulted
on their content. The minutes do not reflect the position of the Commission and cannot be
quoted as such.
Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË – Tel. +32 22991111
For both documents listed above, a 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 personal data.
Article 9(1)(b) of the Data Protection Regulation1 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
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, we conclude that pursuant to the combined provision of the Articles and
Regulations quoted above, access cannot be granted to the personal data contained in the
requested documents.
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 portal2 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 e-mail to: xxxxxxxxxx@xx.xxxxxx.xx
Yours sincerely
Electronically signed
Head of Unit
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.
2
https://www.ec.europa.eu/transparency/documents-request
2
Electronically signed on 29/06/2023 16:53 (UTC+02) in accordance with Article 11 of Commission Decision (EU) 2021/2121
