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Document lifecycle : General aspects
Please find hereafter Frequently Asked Questions about the
general aspects of the document lifecycle.
Frequently Asked Questions on other aspects
FAQ on Gathering
FAQ on Registration
FAQ on Processing
FAQ on Distribution
FAQ on Analysis
FAQ on Access to file
How to handle documents ? (Document Management in the Commission and
in DG COMP)
Handling of e-mails
Cabinet Requests
Courrier du Président (CDP, President's mail)
Personal deliveries?
Trainings
Contact
COMP APPLICATIONS SUPPORT
How to handle documents ? (Document Management in the Commission and in
DG COMP)
Document Management in the Commission are known as the
e-Domec rules.
One of the main ideas is the
Registration
Registration is...
Registration is the action to
identify a document with certainty
acknowledge the sending or the reception of a document
incorporate it into the EC archiving system (the "Register")
In practice, it means to
describe the document and its attachments with metadata
assign a unique identifier, the Registration number
upload the document into ARES (the EC standard registration system) or equivalent system.
link it to a File (which is part of the EC Filing Plan)
Registration
ensures integrity and preservation of documents (contrary to keeping documents in a working space (mailbox,
shared drives));
ensures that important documents are quickly and easily retrieved;
is essential for the efficiency of the institution, for business continuity;
is an essential prerequisite when the Commission needs to provide documentary proof of its action or when
handling a request for access
Which documents need to be registered ?
Criterias
Documents which meet all following 3 criteria :
1. document is
drawn up or received by the institution:
a) documents drawn up by the institution that have been approved as ready by a person who takes responsibility for its
content and
b) documents intentionally delivered to the Commission;
2. document is
related to the policies, activities and decisions falling within the institution's responsibility; and
3. information contained in the document is
important and not short-lived (would losing the information have negative
administrative or legal effect for the Commission? Does the document require action or follow-up or involve
responsibility of the institution?)
In Competition law enforcement,
the Commission actions are subject to
scrutiny from the Court, the complainants, the Ombudsman or other stakeholders. Only
documents that are part of the file can be used as evidence and invoked in defence of the case at the Court (whether concerning
substance or procedures).
Accordingly, the document management is of core importance for handling of a competition case. All documents that make the case
file are registered (if a document is not registered, it is not part of the case file). In antitrust and merger control areas the parties
also have right to
access to the file (with the exception of internal documents, busienss secrets and other confidential information)
and the notion of the file is spelled out in the case law and accordingly reflected in the access to file notice :
The Commission file...
"
The ‘Commission file’ in a competition investigation (hereinafter also referred to as ‘the file’) consists of all documents, which
have been obtained, produced and/or assembled by the Commission Directorate General for Competition, during the
investigation. The term ‘document’ is used for all forms of information support, irrespective of the storage medium. This covers
also any electronic data storage device as may be or become available." (§8)
Following types of internal documents are sometimes missing from the case files, and should be registered :
Examples
meeting notes/minutes (state of play meetings, meetings or telephone conversations with parties on substance matters
etc.);
Advisory Committee documentation (appointment of rapporteur, dispatch of documents, minutes);
final advice of CET;
report from the panel to the Director General;
Following types of documents are
not to be registered :
Examples
drafts (not validated by the person who takes responsibility);
informal exchange of views (e-mails between colleagues and the texts circulated in such exchanges, such as
exchanges with the desk officer in a coordination unit or with Legal Service desk officer - unless the case team decides
that certain communications contain essential information that needs to be kept );
short lived matters (invitations, correspondence on practicalities in organisation of meetings teleconferences etc.)
In horizontal matters,
it is more difficult to outline types of documents to be registered, because the tasks vary. In addition to the registration criteria
outlined above,
keep trace of conclusions reached and of reasons for the decisions
correspondence with external parties (both inside and outside the Commission).
Examples
minutes of weekly meetings with the Commissioner
minutes of various DG COMP internal meetings
where decisions are taken or guidance provided (OCM, SMM,
ATMM, MMM, SAMM, DIT)
documents of various working groups (often using collaborative space for working drafts, but final output should be
registered under a HT file)
conclusions (including minutes) from the ECN working groups and other ECN meetings (registration of such ECN
documents is recurrently reviewed with unit A4 and further quidance will be provided)
minutes of important meetings on specific projects
Registration in DG COMP
In order to ensure integrity, preservations and completeness of documents in a case file or horizontal task file, DG COMP has opted
since years for a model complementary to the standard one used in Commission (decentralised, based purely on ARES), which is
also taken into consideration by the Secretariat General:
DG COMP
own Case Management Applications, used for both case and non-case related files, which embeds a specific
document management system –
EDMA: EDMA has been recognised by the Secretariat General as e-Domec compliant
and is integrated with ARES; supports DG COMP project organisation and the related Need to Know access principle;
offers specific functions needed by DG COMP (e.g. access to file, reporting) and links with specific applications (e.g. SANI,
ECN-I, eDiscovery, Petra, Collaborative workspace, K-drive, eTrustEx)
a
centralised registration system: specific teams in the Registry that are dedicated to registration to ensure coherence,
independent check of the documents (to observe that the registration criteria are respected) and to achieve economies of
scale.
Therefore, the corporate document management system ARES is not used in DG COMP the standard way, and its component
ARESLook is not needed (not installed in DG COMP).
Management of documents that do not meet the registration criteria
A substantial part of the knowledge in DG COMP is included in
internal mail exchange. The draft documents and internal e-mail
exchanges do not meet the eDomec registration criteria as they are drafts, contain informal exchanges of views or are exchanges
on short lived matters.
Those exchanges are also important for
continuity of the business, both within cases/ horizontal tasks (e.g. in view of changes in
the teams – staff leaving and joining the teams) and between tasks (management of knowledge of a topic and finding examples).
This is particularly important for functioning of the DG COMP matrix organisation.
That knowledge should not be lost for the team and DG COMP overall.
Guidance :
Case and horizontal task documents that are not to be registered: To be stored either in
(re
Collaboration workspaces
commended option for new cases) or
, where case/horizontal task teams themselves store the
in K:drive
working/intermediary and background documents, including e-mails.
Unit activity documents (e.g. unit meetings/events, organisational matters of the unit): These unit specific documents are
usually stored S: drive (since H:\ migration to S:\ on 12/09/2016).
A better alternative is to also use the K:\ drive, where access rights can be managed directly by the Head of Unit by
defining the team of the related HTs. Therefore, some additional HTs can be created : eg. Unit social activities, Unit HR
(hidden), Unit past cases, Sector Knowledge, etc.
(more information available here)
Manuals and guidance information: Stored in
DG COMP's Wiki, where information is managed by the relevant
responsible Unit.
More information
SEC(2009)1643. Implementing rules for the decision 2002/47/EC, ECSC, EURATOM on document management and for the decision
2004/563/EC, EURATOM on electronic and digitised documents. 30/11/2009
The Commission
on access to File - Commission Notice on the rules for access to the Commission file in cases pursuant to
Notice
Articles 81 and 82 of the EC Treaty, Articles 53, 54 and 57 of the EEA Agreement and Council Regulation (EC) No 139/2004, OJ of
22.12.2005, C-325/7 explains the principles relating to access to file as well as the treatment of confidential information
Document Management and access to documents.
to Directors General, Heads of Cabinet and Directors of Executive
Note
agencies. ARES(2015)182108
An introduction to Document Management in COMP as part of
the Newcomers training
the Induction Training cycles :
Antitrust
Handling of e-mails
Click here to expand...
From
1 July 2015, emails
older than 6 months will be
deleted if stored in
Inbox, and subfolders
Sent items, and subfolders
Deleted items, and subfolders
This applies both to your personal mailbox
and to functional mailboxes (Unit mailboxes, ...)
This will also apply if you are
on holiday on 1 July (but not for maternity or sick leave).
Additional information is available
here.
What to do ?
Register important emails
As any other document, emails containing important information, not short-lived should be registered.
In COMP, it's very easy and takes you only a few seconds :
* Put the Registry in copy to outgoing emails
* Forward the email
to your Registry, mentioning the File reference (case number or HT reference) :
as attachment
- "COMP GREFFE ANTITRUST"
- "COMP MERGER REGISTRY"
- "COMP STATE AID GREFFE"
Other emails you want to keep
Use the K-drive or Collaboration space of the relevant File (case or HT) to store those
For horizontal matters for which no file is available, create new folders directly within your mailbox (not under "Inbox" or
"Sent Items"). see How to.
Cabinet Requests
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From Feb 3rd 2014, Cabinet Requests (and CDP) will be handled through ARES, and especially with the e-Signatory function.
Please consult the
dedicated page.
Here is the training material : e-Signatory for Cabinet Requests & CDP
Courrier du Président (CDP, President's mail)
Click here to expand...
From Feb 3rd 2014, Cabinet Requests (and CDP) will be handled through ARES, and especially with the e-Signatory function.
Please consult the
dedicated page
Here is the training material : e-Signatory for Cabinet Requests & CDP
Personal deliveries?
Please click here to expand...
We ARE NOT ALLOWED TO RECIEVE CD, DVD, paper documents directly. Please see instructions below:
Special care should be taken if we are receiving sensitive information. In order to follow Art. 3.3 Commission Regulation (EC) No 794/2004,
from 1 July 2008, "all correspondence in connection with a notification shall be transmitted electronically via the secured e-mail system Public
Key Infrastructure (PKI)".
Below 4MB: Registries should receive secured emails encrypted using "Qualified PKI Certificates" which can be used below 4 MB
(before encryption). On the DG COMP website ("Contact"), external parties can find
information how to obtain such certificate via
certificates providers or any national certification authority.
Under 4MB: Registries should receive a PKI email and the cover letter should contains the information about the documentation that
will be received and that the annexes will be sent via post in a digital device (usually a CD/DVD). The registries will this cover e-mail
in the case with corresponding the sending date and will wait for the arrival of the CD to complete the registration.
For security reasons, since 2001, documents can never be delivered in person directly to the EC buildings. They will be filtered to a central
Registry which will then dispatch it to the relevant service.
Colleagues in DG COMPETITION are reminded not to have private parcels nor private letters sent to DG COMPETITION. Neither by normal
nor registered mail
The mail clerks and the Registries do not have the capacity to handle private deliveries, nor is it their task to handle these
It is not always obvious whether a parcel is indeed private or work-related and thus for one of the Registries to handle
Thank you for respecting this
Trainings
Click here to expand...
Several trainings are regularly organised :
Newcomers : within the general training for Newcomers, an introduction to Document Management in COMP
Find
here also the introduction on information and document management tools used in COMP, part of the Newcomers package.
Document Management introduction, as part of the Induction Training cycles :
Antitrust - Merger
Exchanges with other DGs (ARES)
Practical Access to file
Document Outline
