Reference to privacy statement of the European Commission
Processing operation: Processing of personal data linked to meetings and events
Data Controller: European Commission, Directorate-General for Communications Networks, Content and Technology (Connect), Unit G3: Accessibility, Multilingualism & Safer Internet
Record reference: DPR-EC-1063
1. Introduction
The European Commission is committed to protect your personal data and to respect your privacy. The Commission collects and further processes personal data pursuant to Regulation (EU) 2018/1725 of the European Parliament and of the Council 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.
This privacy statement explains the reason for the processing of your personal data in the context of the final event for the “Support to increase cooperation among industry, NGOs, and Member States’ authorities for the swift removal of child sexual abuse material online” (hereafter “Swift Removal of CSAM”) with the contract number CNET/LUX/2020/OP/0059, coordinated by PwC EU Services together with the Expertisebureau Online Kindermisbruik EOKM and the European Service Network ESN (hereafter referred to as the Data Processor/Contractor) for the Directorate-General for Communications Networks, Content and Technology, Unit G3 Accessibility, Multilingualism and Safer Internet of the European Commission (hereafter “the Commission”). It explains the way we collect, handle and ensure protection of all personal data provided, how that information is used and what rights you have in relation to your personal data. It also specifies the contact details of the responsible Data Controller with whom you may exercise your rights, the Data Protection Officer and the European Data Protection Supervisor.
The information in relation to the processing of personal data linked to meetings and events, organised by the services of the European Commission, is presented below.
2. Why and how do we process your personal data?
Purpose of the processing operation: the European Commission collects and further processes your personal data to provide you with information about the “Swift Removal of CSAM” final event (before, during and after) and to process your application for participation in that event.
Your personal data will not be used for any automated decision-making including profiling.
As a result of the “Swift Removal of CSAM” final event, photos/screenshot captures and audio-visual recordings including the organisers, participants and contributors could be uploaded and published in the context of the communication campaign on Social Media platforms (e.g. LinkedIn, Twitter) and websites of the organisers or relevant stakeholders, and specifically the website of the EOKM.
Should you register to take part in the “Swift Removal of CSAM” final event, this event will be recorded. In this case, all speakers, moderators and registered participants will give consent to have their image and voice being recorded and broadcasted if, during the event, they decide to enable their camera or microphone. Meanwhile, all participants who would register for the “Swift Removal of CSAM” final event, give their consent to their names being visible to other participants across the various sessions and their names and email addresses would also be kept for internal reporting and organisational purposes.
Participants that do not wish to be part of the above web-streaming and recording/publishing activities have the possibility to object to processing. Turning on the camera during the virtual part of the event is voluntary. Participants that do not wish to be captured by screenshots during the virtual part of the event should turn their camera’s off. During the physical part of the event, a separate place in the room will be foreseen for the participants who opted for not being captured by photo and video.
Photos/screenshot captures and audio-visual recordings will only be used on the basis of your consent as expressed in this form. The Data Controller and Data Processor may be contacted at any time to withdraw consent for the use of your photos/recordings or to object to a processing (please refer to their contact details under Heading 9 below). Photos and recordings would then be removed from wherever they have been posted as soon as is practical. Please be aware that it may be impossible to remove your likeness where it has been included in a printed publication which has already been published or is in the process of being published. Such images would only be removed from future publications. If a deletion request is sent, we may ask for further identity information in order for us to be able to verify your identity.
3. On what legal ground(s) do we process your personal data
The processing operations on personal data, linked to the organisation, management, follow-up and promotion of the “Swift Removal of CSAM” final event (including web-streaming, photos, audio-visual recording) are necessary for the management and functioning of the Commission, as mandated by the Treaties. Those provisions are in particular, Article 11 of the Treaty on European Union and Article 15 of the Treaty on the Functioning of the European Union.
Consequently, those processing operations are lawful under Article 5(1)(a) of Regulation (EU) 2018/1725 (processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Union institution or body).
Your consent is required for the following actions during the “Swift Removal of CSAM” final event:
- the processing of your personal data relating to your dietary requirements and/or access requirements (only for the physical part of the final event);
- the processing of audio-visual recording including the sharing of your photos/screenshot captures on social media platforms such as LinkedIn and Twitter and on the website of the EOKM;
- the sharing of the meeting or event participants list containing your name and affiliation with other participants. In addition, further information will be given if there are specific purposes for such sharing (e.g. for the purpose of future collaboration);
- the sharing of the meeting/event attendee list containing your name and affiliation among participants, in order to create working groups to continue the collaborate work launched during the meeting/event;
- the processing of your personal data for inviting you to future events the data controller may organise.
If you opt-in, you are giving us your explicit consent under Article 5(1)(d) of Regulation (EU) 2018/1725 to process your personal data for those specific purposes. You can give your consent via a clear affirmative act by ticking the box(es) on the online registration form.
If you would like to opt-out for a specific action, please send an email to fg@eokm.nl with the relevant information.
Your consent for these services can be withdrawn at any time and detailed information on how to withdraw consent will be contained in the privacy statement linked to the specific meeting or event.
If you have any further questions regarding the collection and use of your personal data in the context of the “Swift Removal of CSAM” final event, please contact us at fg@eokm.nl. If required, the Data Processor/Contractor will transfer your questions to the contracting authority and Data Controller.
4. Which personal data do we collect and further process?
The following personal data may be processed in the context of the meeting or event:
- contact details (first name, last name, name of organisation, country, e-mail address);·
- dietary requests (if any) or specific access requirements (only for the physical part of the final event).
5. How long do we keep your data?
The Data Controller only keeps your personal data for the time necessary to fulfil the purpose of collection or further processing.
For each of the categories of personal data that may be processed, please find below the retention details and the reference to the relevant record of processing:
- Personal data related to the organisation and management of the “Swift Removal of CSAM” final event (this includes the information given during the registration, before, during or after the event) will be kept for five years after the meeting or event.
- Sensitive personal data relating to dietary and/or access requirements will be deleted as soon as they are no longer necessary for the purpose for which they have been collected in the framework of the meeting or event, but no later than within 1 month after the end of the meeting or event.
- Recordings from the web-streamed meeting or event will be kept for 2 years before being deleted. More information is available in the Record of Processing DPR-EC-00306 (Web-streaming of Commission events).
- In case of audio-visual recording of the “Swift Removal of CSAM” final event, the recordings will be kept for 3 months after the meeting or event before being deleted. More information is available in the Record of Processing DPR-EC-01937 (Audio-visual recording of meetings).
- Selected service providers for organisational purposes (such as caterers, travel agents or event management organisations) are contractually bound to process personal data on behalf of and in line with the instructions of the data controller, keep confidential any data they process and protect it from unauthorised access, use and retention.
6. How do we protect and safeguard your personal data?
All personal data in electronic format (e-mails, documents, databases, uploaded batches of data, etc.) are stored on the servers of the European Commission (or of its contractors, if contractors are engaged to assist the controller in the organisation and management of a specific meeting or event). All processing operations are carried out pursuant to Commission Decision (EU, Euratom) 2017/46 of 10 January 2017 on the security of communication and information systems in the European Commission.
In order to protect your personal data, the Commission has put in place a number of technical and organisational measures. Technical measures include appropriate actions to address online security, risk of data loss, alteration of data or unauthorised access, taking into consideration the risk presented by the processing and the nature of the personal data being processed. Organisational measures include restricting access to the personal data solely to authorised persons with a legitimate need to know for the purposes of this processing operation.
The Data Processor/Contractor is bound by a specific contractual clause for any processing operations of your personal data on behalf of the Commission. Therefore, it has put in place appropriate technical and organisational measures to ensure the level of security, required by the Commission.
7. Who has access to your personal data and to whom is it disclosed?
Access to your personal data is provided to the staff of the Data Processor/Contractor and the Commission staff responsible for carrying out this processing operation and to other authorised Commission staff according to the “need to know” principle. Such staff abide by statutory, and when required, additional confidentiality agreements.
8. Cookies
Cookies are short text files stored on a user’s device (such as a computer, tablet or phone) by a website. Cookies are used for the technical functioning of a website (functional cookies) or for gathering statistics (analytical cookies).
The online registration form will take place at https://www.esurveyspro.com/
For the session ID cookie, once users close the browser, the cookie simply terminates. A persistent cookie is a small text file stored on the Site Visitor's hard drive for an extended period of time. Persistent cookies can be removed by following Internet browser help file directions (see below). The session cookies ensure that only people who have entered in correct login details are able to use password-protected areas, and only areas that they are authorized to use. Persistent cookies enable to track and target the interests of users to enhance the experience on the site.
When you visit the site, the cookies are used to store data on your device. This is so to:
- Distinguish you from other users of the website.
- Improve the website's performance and your experience of using the website.
- Make it easier and more convenient for you to log in to the site, by storing the username and password on your device.
- To ensure secure login.
- In certain surveys under the Account Holder's direction, to ensure that a survey respondent can't retake the same survey more than once.
- To track referral data and see how you got to the site.
- To measure your usage of the proposed services.
9. International transfers
Photos/recordings will be stored in a secure environment and in line with our obligations under EU Regulation 2018/1725. Your information is not intended to be transferred to destinations outside of the EU/EEA, although it may be accessible to parties outside of the EU/EEA via online media and websites.
The information we collect will not be given to any other third party, except to the extent and for the purpose we may be required to do so by law.
10. What are your rights and how can you exercise them?
You have specific rights as a ‘data subject’ under Chapter III (Articles 14-25) of Regulation (EU) 2018/1725, in particular the right to access, your personal data and to rectify them in case your personal data are inaccurate or incomplete. Where applicable, you have the right to erase your personal data, to restrict the processing of your personal data, to object to the processing, and the right to data portability.
You have the right to object to the processing of your personal data, which is lawfully carried out pursuant to Article 5(1)(a) of Regulation (EU) 2018/1725 on grounds relating to your particular situation.
The European Commission will ensure that the data subjects can exercise their right to object to processing whenever possible by the organisers of the meeting/event (for example, on the spot by indicating a non-web streamed seat if requested; or ex-post, by deleting a specific sequence from the online video/voice recording).
In line with information provided under Heading 3, you have consented to provide your personal data for a number of specific processing operations. You will be able to withdraw your consent at any time by notifying the Data Controller using the contact details specified under Heading 9. The withdrawal of your consent will not affect the lawfulness of the processing carried out before you have withdrawn the consent.
You can exercise your rights by contacting the data controller, or in case of conflict the Data Protection Officer. If necessary, you can also address the European Data Protection Supervisor. Their contact information is given under Heading 9 below.
Where you wish to exercise your rights in the context of one or several specific processing operations, please provide their description (i.e., their Record reference(s) as specified under Heading 10 below) in your request.
11. Contact information
- The Data Controller
If you would like to exercise your rights under Regulation (EU) 2018/1725, or if you have comments, questions or concerns, or if you would like to submit a complaint regarding the collection and use of your personal data, please feel free to contact the Data Controller (CNECT-G3@ec.europa.eu), whose contact details will be provided in the specific privacy statement linked to the “Swift Removal of CSAM” final event.
- The Data Protection Officer (DPO) of the Commission
You may contact the Data Protection Officer (DATA-PROTECTION-OFFICER@ec.europa.eu) with regard to issues related to the processing of your personal data under Regulation (EU) 2018/1725.
- The European Data Protection Supervisor (EDPS)
You have the right to have recourse (i.e. you can lodge a complaint) to the European Data Protection Supervisor (edps@edps.europa.eu) if you consider that your rights under Regulation (EU) 2018/1725 have been infringed as a result of the processing of your personal data by the data controller.
12. Where to find more detailed information?
The Commission Data Protection Officer (DPO) publishes the register of all processing operations on personal data by the European Commission, which have been documented and notified to him. You may access the register via the following link: http://ec.europa.eu/dpo-register.
This specific processing operation has been included in the DPO’s public register with the following Record reference: DPR-EC-1063.