Dear Office For Administration And Payment Of Individual Entitlements,

Under the right of access to documents enshrined in Article 15 of the Treaty on the Functioning of the European Union (TFEU) and implemented by Regulation (EC) No 1049/2001 regarding public access to European Parliament, Council, and Commission documents, I hereby submit the following request.

I am seeking access to documents containing detailed information regarding the travel expenses of the following individuals for the period from 1 January 2012 to 31 December 2018, inclusive:

Mr Giovanni Kessler, former Director-General of OLAF and later Advisor in DG BUDG,

Mr Thibaut Kleiner, Director of DG CNECT

Ms Charlotte Arwidi, OLAF staff member, formwr assistant of DG Kessler

In this light, and in view of the general interest in transparency regarding the use of public funds and the avoidance of any potential conflicts of interest, I respectfully request that, where applicable, the documents also provide information on whether any trips were undertaken jointly by these persons, and whether any expenses might reflect joint travel arrangements, overlapping mission periods, or combined missions.
Specifically, I request access to documents containing, for each trip:

The place of origin and destination of each trip;

The exact dates and duration of the trip;

The amount spent on travel or transportation;

The amount spent on accommodation;

The amount spent on subsistence;

Any other costs incurred (e.g., local transportation, visa fees, registration fees, miscellaneous expenses), with a detailed description where available.

I request that the documents provided contain sufficient details to be able to identify for each type of miscellaneous cost (what the money was spent on) and the total amount (in local currency and/or in Euros) for each item.

If the travel was by air taxi and a team of people were travelling, please also provide documents with details on the other travellers (at a minimum, names and job titles).

With respect to personal information contained in any documents that you might have, I note that the only information being sought here is the name and surname of the persons mentioned above, something which is already in the public domain. This request does not seek access to any other personal information such as bank account details. Nor am I requesting data such as the office addresses, signatures or telephone numbers of the staff members

.Please also take into consideration the following when evaluating the request:
i) In order to ensure that the European Commission is both transparent and accountable with respect to the spending by public senior officials of public funds while on public business, it is absolutely essential that details of what the money was spent on be made public.  It is impossible for a member of the public to evaluate whether funds are being spent appropriately on travel, accommodation, meals, and other related costs, without knowing from where and to where someone travelled and for what length of time. To exclude details on to where and for what time period missions were undertaken deprives the European public of essential information necessary to scrutinise the spending of public funds.
ii) ) Senior officials of the European Commission must uphold and be seen to uphold the highest standards of integrity, prudence, and accountability. Transparency regarding the use of public funds by such officials is crucial, not only to verify that expenditures are lawful and appropriate, but also to avoid any perception of undue influence, conflicts of interest, or misuse of resources. In times of widespread economic hardship across Europe, it is particularly vital that the institutions of the European Union demonstrate through concrete evidence that public funds are managed responsibly and with the utmost care. Ensuring transparency is indispensable both for securing accountability and for strengthening — or even restoring — the public’s confidence in the European institutions.
The right of access to documents as established in the EU treaties has at its heart the goal “to promote good governance and ensure the participation of civil society”. High levels of transparency on spending are necessary to achieve that goal. Hence, while generally there is an onus on the requester to demonstrate the necessity of transferring data that falls under the scope of Regulation 45/2001, there should be a general presumption of the necessity of transferring data that is essential to ensuring accountability by the public of the spending of public funds. 
With respect to the necessity of having the information above transferred to me in my role as Researcher and Campaigner at Access Info Europe, we as an organisation are working on a number of projects relating to transparency of public activity, including spending of public funds. In this context and in the context of our involvement in international initiatives such as the Open Government Partnership as well as our work on transparency of lobbying, we have a particular interest in spending by senior public officials and elected representatives. We are conducting research in this area across Europe, and are also working with journalists interested in obtaining such information.
In this context, the requested information is being sought in the general public interest, in order to contribute to transparency, good administration, and accountability within the European Commission. The information is essential for enabling civil society, researchers, journalists, and the wider public to exercise effective oversight of the use of public funds and to ensure that senior officials act, and are seen to act, with the highest standards of probity.

There are no grounds to assume that the legitimate interests of the data subjects — in particular their right to privacy and personal integrity — would be adversely affected by the disclosure of the requested information. The individuals concerned are senior officials of the European Commission, occupying top-level public positions, about whom substantial information is already available in the public domain. Moreover, the travel and meetings of such officials are frequently subject to proactive transparency measures. Consequently, there is nothing inherently private about their official travel: neither the destinations, nor the dates, nor the accommodation arrangements, nor, in many cases, the locations where they dine or are otherwise provided with refreshments and hospitality.
Accordingly, no specific or adverse effect on their legitimate interests would arise from the disclosure of information concerning their travel and associated costs. Likewise, the publication of amounts spent on travel, accommodation, subsistence, and other mission-related expenses, even when linked to the name of an individual official, would not in itself disclose anything pertaining to their private lives. It concerns the use of public funds for official purposes, which must be subject to public scrutiny.
Even if it were argued that disclosure could potentially lead to public commentary or criticism, it must be emphasised that such possibilities are an inherent and necessary feature of democratic accountability. Furthermore, it must be recognised that non-disclosure of this information could be even more damaging. In this respect, the situation is comparable to that examined by the Court in the ClientEarth case, where it was found that publication of information was likely to be less harmful than withholding it. As the Court observed, disclosure could dispel suspicions of partiality and allow those concerned to challenge any unfounded allegations through available legal remedies.
Similarly, in the present case, continued non-disclosure of detailed information about the expenses of senior officials risks fostering an environment of suspicion and mistrust, in which unverified or false allegations may circulate. By contrast, full transparency through disclosure would serve to protect the integrity of the officials concerned by allowing the public to verify that public funds are being used appropriately and in accordance with the highest standards of propriety.

Yours faithfully,

kristen novak