Ref. Ares(2023)4116257 - 14/06/2023
EUROPEAN COMMISSION
DIRECTORATE-GENERAL FOR AGRICULTURE AND RURAL DEVELOPMENT
Directorate I – Legal, procedural and inter-institutional affairs
I.1 – Agricultural law and enforcement
Brussels
AGRI.I.1/RW D(2023)
Subject:
Your application for access to documents Case 2023/2981
Dear Ms JORDAN,
We refer to your request for access to European Commission documents registered on
23/05/2023 under the above-mentioned reference number.
You request access to:
All documents - including but not limited to minutes, (hand-
written) notes, audio recordings, verbatim reports, operational conclusions, lines to take,
e-mails, and presentations, correspondence (i.e. any emails, correspondence, telephone
call notes, and/or text messages including WhatsApp exchanges) – related to the
following meetings:
1. Joanna Stawowy and Hill & Knowlton International Belgium on 28-03-2023
2. Wolfgang Burtscher and Bayer on 28-11-2022
We have identified 4 documents with annex falling within the scope of your request. You
will find enclosed a list of the documents identified, as well as copies of the
aforementioned 4 documents and annexes.
With regard to the documents mentioned above, a complete disclosure of them 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;
-
handwritten signatures/abbreviated signatures of natural persons;
In your application, you indicate that your address is outside of the EU. Transfers of
personal data from the Commission to countries that are not members of the European
Ms Lucy JORDAN
Canonbury Villas,
London, 1N
United Kingdom
xxxxxxxxxxxxxxxxxxxxxxxxxx@xxxxxxxx.xxx
Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË – Tel. +32 22991111
Economic Area (EEA), or to international organisations are regulated under Chapter V of
the Data Protection Regulation[1].
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, it is not established that these conditions are fulfilled.
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.
Article 9(1)(b) of the Data Protection Regulation does not allow the transmission of this
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, 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.
You may reuse the documents disclosed free of charge and for non-commercial and
commercial purposes provided that the source is acknowledged and that you do not
distort the original meaning or message of the documents. Please note that the
Commission does not assume liability stemming from the reuse.
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 portal1 account (available only for initial requests
submitted via the portal account),
or by mail:
[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.
1
https://www.ec.europa.eu/transparency/documents-request
2
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
Yours faithfully,
Cristina Carrasco Lorente
Head of Unit
Enclosure:
4 documents with annex
3
Electronically signed on 14/06/2023 10:19 (UTC+02) in accordance with Article 11 of Commission Decision (EU) 2021/2121
