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EDPB & Clearview AI investigations by Greece, Italy, France

Lydia Emmanouilidou made this access to documents request to European Data Protection Board 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.

We're waiting for Lydia Emmanouilidou to read recent responses and update the status.

Lydia Emmanouilidou

Dear European Data Protection Board,

Over the past few years competent authorities in various European Union states - including Greece, Italy, and France - have investigated and imposed fines on the private company Clearview AI over illegal data collection and other violations [1,2,3].

Under the right of access to documents in the EU treaties, as developed in Regulation 1049/2001, I am requesting from the European Data Protection Board (henceforth EDPB) documents which contain the following information:

From 01 January 2024 to present:

1) All documents containing the keyword ‘Clearview.’
2) All documents (including briefings, notes, minutes of meetings, papers, non-papers, reports, powerpoints, or informal input) related to the Clearview AI investigations in Greece, Italy and France; ensuing decisions; and attempts by competent member state authorities to enforce the imposed fines
3) All correspondence created or held by the EDPB related to the aforementioned Clearview AI investigations, decisions, and attempts by competent EU member state authorities to enforce the imposed fines (including letters and emails, and any attachments) exchanged:

3a) Between employees at the EDPB
3b) Between employees of the EDPB and Clearview AI
3c) Between employees of the EDPB and other competent EU member state authorities

Please be advised that this request EXCLUDES documents related to the Dutch investigation and fine against Clearview AI - as I have a separate ongoing request with the EDPB on the matter.

If you have any questions or concerns about this request, please do not hesitate to contact me by email at [email address] or by phone at +69 47 13 0775. I would be happy to discuss this request to make it as manageable as possible for your team to process. Thank you!

[1] https://www.edpb.europa.eu/news/national...

[2] https://www.edpb.europa.eu/news/national...

[3] https://www.edpb.europa.eu/news/national...

Lydia Emmanouilidou

European Data Protection Board

Dear Sir/Madam,

 

Thank you for your message and for your interest in data protection.

We will look into your request and get back to you within due time.

 

Kind regards,

The EDPB Secretariat

Lydia Emmanouilidou

Dear European Data Protection Board,

Thank you for your reply of 31 October 2024. I am checking in on this request to ensure it is registered in a timely manner. Could you please confirm if it has been registered? I am at your disposal if I can help in any way.

Yours faithfully,

Lydia Emmanouilidou

European Data Protection Board

Dear correspondent,

Thank you for your email.

In accordance with Article 6(1) of Regulation 1049/2001, applications for access to a document shall be made in a sufficiently precise manner to enable the institution to identify the document.

The EDPB would incur a disproportionate workload in order to carry out the assessment of the documents potentially in scope of your request, based on the information you have provided in your message below. In this respect, Article 6(3) of Regulation (EC) No 1049/2001 regarding public access to documents also provides for a possibility to confer with an applicant informally with a view to finding a fair solution when an application relates to a very long document or concerns a very large number of documents.

Based on the above-mentioned provision, we would kindly ask whether you could provide us with more precise information on the documents you request and narrow down the scope of your application (i.e. the subject matter(s) and/or timeframe covered), so as to reduce it to a more manageable amount of documents in a way that would enable its processing within the established deadlines of Regulation 1049/2001.

We kindly ask you to provide these clarifications so that we may identify the documents in scope of your request. Please note that this request will be considered closed if no reply is received within 15 working days (i.e. by 27/11/2024). Of course, this does not prevent you from making another request at any stage in the future.

Thank you for your cooperation.

Kind regards,
The EDPB Secretariat

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Lydia Emmanouilidou

Dear European Data Protection Board,

Thank you for your reply. Would it be possible to speak over the phone this week with the person handling this request to come up with a viable solution? Otherwise I will make a suggestion by Friday. Thank you.

Yours sincerely,

Lydia Emmanouilidou

Lydia Emmanouilidou

Dear European Data Protection Board,

In response to your request, I am suggesting the following amendments to my request, to make it more manageable for your team to process.

Firstly, I am suggesting narrowing the timeframe of the request. Secondly, I am eliminating the first bullet point of the request (“1) All documents containing the keyword ‘Clearview.’”). Thirdly, I am suggesting that this request be processed in three parts: one relating the investigation by Greece, the second relating to the investigation by France, and the third to the investigation by Italy (in the order that suits you most).

The amended request follows as such:

Over the past few years competent authorities in various European Union states - including Greece, Italy, and France - have investigated and imposed fines on the private company Clearview AI over illegal data collection and other violations [1,2,3].

Under the right of access to documents in the EU treaties, as developed in Regulation 1049/2001, I am requesting from the European Data Protection Board (henceforth EDPB) documents which contain the following information:

From 01 April 2024 to present:

1) All documents (including briefings, notes, minutes of meetings, papers, non-papers, reports, powerpoints, or informal input) related to the Clearview AI investigations in Greece, Italy and France; ensuing decisions; and attempts by competent member state authorities to enforce the imposed fines

2) All correspondence created or held by the EDPB related to the aforementioned Clearview AI investigations, decisions, and attempts by competent EU member state authorities to enforce the imposed fines (including letters and emails, and any attachments) exchanged:

3a) Between employees at the EDPB
3b) Between employees of the EDPB and Clearview AI
3c) Between employees of the EDPB and Greek, Italian and Dutch French authorities

Please be advised that this request EXCLUDES documents related to the Dutch investigation and fine against Clearview AI - as I have a separate ongoing request with the EDPB on the matter.

Please also be advised that this request could be split into three parts: one relating the investigation by Greece, the second relating to the investigation by France, and the third to the investigation by Italy (in the order that suits you most).

If you have any questions or concerns about this request, please do not hesitate to contact me by email at [email address] or by phone at +69 47 13 0775. I would be happy to discuss this request to make it as manageable as possible for your team to process. Thank you!

[1] https://www.edpb.europa.eu/news/national...
[2] https://www.edpb.europa.eu/news/national...
[3] https://www.edpb.europa.eu/news/national...

Yours sincerely,

Lydia Emmanouilidou

European Data Protection Board

Dear correspondent,

we accept your proposal to narrow down the scope of application, as indicated in your email of 8 November.

We confirm registration of your access to documents request and registered it today under reference 2024-34. Please use this reference for further correspondence.

We are currently assessing your request and will provide you with a reply within 15 working days (29/11/2024).

Please note that the EDPB specific privacy statement regarding the processing of personal data for the purposes of handling requests for access to documents is available on the EDPB website and can be viewed via this link: https://edpb.europa.eu/edpb-specific-pri...

Should you have any further queries, please do not hesitate to contact us.

Best regards,

The EDPB Secretariat

[EDPB request email]
European Data Protection Board
Postal address: Rue Wiertz 60, B-1047 Brussels
Office address: Rue Montoyer 30, B-1000 Brussels
edpb.europa.eu

This email (and any attachment) may contain information that is internal or confidential. Unauthorised access, use or other processing is not permitted. If you are not the intended recipient please inform the sender by reply and then delete all copies. Emails are not secure as they can be intercepted, amended, and infected with viruses. The EDPB therefore cannot guarantee the security of correspondence by email.

________________________________________
From: Lydia Emmanouilidou
Sent: Friday, November 8, 2024 1:06:37 PM (UTC+01:00) Brussels, Copenhagen, Madrid, Paris
To: European Data Protection Board
Subject: RE: access to documents request - EDPB & Clearview AI investigations by Greece, Italy, France

+--------------------------------------------------------------------------------------------------+
| This email is from an external sender. Be cautious when opening links or attachments |
+--------------------------------------------------------------------------------------------------+
Dear European Data Protection Board,

In response to your request, I am suggesting the following amendments to my request, to make it more manageable for your team to process.

Firstly, I am suggesting narrowing the timeframe of the request. Secondly, I am eliminating the first bullet point of the request ("1) All documents containing the keyword 'Clearview.'"). Thirdly, I am suggesting that this request be processed in three parts: one relating the investigation by Greece, the second relating to the investigation by France, and the third to the investigation by Italy (in the order that suits you most).

The amended request follows as such:

Over the past few years competent authorities in various European Union states - including Greece, Italy, and France - have investigated and imposed fines on the private company Clearview AI over illegal data collection and other violations [1,2,3].

Under the right of access to documents in the EU treaties, as developed in Regulation 1049/2001, I am requesting from the European Data Protection Board (henceforth EDPB) documents which contain the following information:

From 01 April 2024 to present:

1) All documents (including briefings, notes, minutes of meetings, papers, non-papers, reports, powerpoints, or informal input) related to the Clearview AI investigations in Greece, Italy and France; ensuing decisions; and attempts by competent member state authorities to enforce the imposed fines

2) All correspondence created or held by the EDPB related to the aforementioned Clearview AI investigations, decisions, and attempts by competent EU member state authorities to enforce the imposed fines (including letters and emails, and any attachments) exchanged:

3a) Between employees at the EDPB
3b) Between employees of the EDPB and Clearview AI
3c) Between employees of the EDPB and Greek, Italian and Dutch French authorities

Please be advised that this request EXCLUDES documents related to the Dutch investigation and fine against Clearview AI - as I have a separate ongoing request with the EDPB on the matter.

Please also be advised that this request could be split into three parts: one relating the investigation by Greece, the second relating to the investigation by France, and the third to the investigation by Italy (in the order that suits you most).

If you have any questions or concerns about this request, please do not hesitate to contact me by email at [email address] or by phone at +69 47 13 0775. I would be happy to discuss this request to make it as manageable as possible for your team to process. Thank you!

[1] https://www.edpb.europa.eu/news/national...
[2] https://www.edpb.europa.eu/news/national...
[3] https://www.edpb.europa.eu/news/national...

Yours sincerely,

Lydia Emmanouilidou

show quoted sections

European Data Protection Board

4 Attachments

Dear correspondent,

 

Please find enclosed the reply to your request for access to documents
(ref. 2024-34) signed by Ms Irene Loizidou-Nicolaidou, Vice-Chair of the
EDPB.

 

We kindly ask to confirm receipt of this email.

 

Best regards,

The EDPB Secretariat

 

 

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│ ║ │
│ ║[2]cid:image002.png@01D41CFD.08F58A00 [3][EDPB request email]│
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│ ║European Data Protection Board │
│[1]cid:image001.png@01D41CFD.08F58A00║ │
│ ║Postal address: Rue Wiertz 60, B-1047 Brussels │
│ ║ │
│ ║Office address: Rue Montoyer 30, B-1000 Brussels │
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│ ║[4]cid:image003.png@01D41CFD.08F58A00 [5]edpb.europa.eu │
╞═════════════════════════════════════╩════════════════════════════════════════════════════════════╡
│This email (and any attachment) may contain information that is internal or confidential. │
│Unauthorised access, use or other processing is not permitted. If you are not the intended │
│recipient please inform the sender by reply and then delete all copies. Emails are not secure as │
│they can be intercepted, amended, and infected with viruses. The EDPB therefore cannot guarantee │
│the security of correspondence by email. │
└──────────────────────────────────────────────────────────────────────────────────────────────────┘

 

References

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We don't know whether the most recent response to this request contains information or not – if you are Lydia Emmanouilidou please sign in and let everyone know.