Digital communication tool for EU projects
in Ukraine
Digital communication tool for EU projects
in Ukraine

PRIVACY STATEMENT

EUROPEAN COMMISSION

PROTECTION OF YOUR PERSONAL DATA

This privacy statement provides information about

the processing and the protection of your personal data.

Processing operation: EUDIGITOOL - Digital communication tool for EU projects in the Eastern Neighbourhood countries (Armenia, Azerbaijan, Belarus, Georgia, Republic of Moldova and Ukraine)

Data Controller: Directorate-General for Neighbourhood and Enlargement Negotiations (DG NEAR) /Directorate A / Unit NEAR.A1 Inter-institutional Relations and Communication

Record reference: DPR-EC-07086

The record DPR-EC-07086 covers (1) EUDIGITOOL - Digital communication tool for EU projects in the Eastern Neighbourhood countries (Armenia, Azerbaijan, Belarus, Georgia, Republic of Moldova and Ukraine) and (2) EU projects websites in the Eastern Neighbourhood countries - Armenia, Azerbaijan, Belarus, Georgia, Republic of Moldova and Ukraine under euneighbourseast.eu

Table of Contents

  1. Introduction
  2. Why and how do we process your personal data?
  3. On what legal ground(s) do we process your personal data?
  4. Which personal data do we collect and further process?
  5. How long do we keep your personal data?
  6. How do we protect and safeguard your personal data?
  7. Who has access to your personal data and to whom is it disclosed?
  8. What are your rights and how can you exercise them?
  9. Contact information
  10. Where to find more detailed information?

  1. Introduction

The European Commission (hereafter ‘the 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 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 (repealing Regulation (EC) No 45/2001).

This privacy statement explains the reason for the processing of your personal data, 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 processing operation EUDIGITOOL - Digital communication tool for EU projects in the Eastern Neighbourhood countries (Armenia, Azerbaijan, Belarus, Georgia, Republic of Moldova and Ukraine) undertaken by the Data Controller is presented below.

  1. Why and how do we process your personal data?

Purpose of the processing operation: The Data Controller collects and uses your personal information with the objective to enable DG NEAR, the European External Action Service (EEAS), the EU Delegations and other EU institutions and agencies to generate, manage, publish and archive project information, outputs, outcomes, and overall impact more efficiently and effectively for communication purposes.

The EUDIGITOOL is a digital platform of DG NEAR, developed in collaboration with the EEAS East StratCom Task Force to respond to the need and demand for collating and consolidating project information presenting EU cooperation in action from a communication perspective, namely communication materials, photos, videos, projects and beneficiaries’ contacts etc.

The purpose of the data processing is to:

The tool is an internal system for managing project data. The data is available for display on the EU Delegation and headquarters public interfaces, as required.

All data processing is transparent and abiding to the principle of users opting-in/out, and allowing the data they provide to be used for specific purposes.

Your personal data will not be used for an automated decision-making including profiling.

  1. On what legal ground(s) do we process your personal data

We process your personal data because the 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 (Article 5 (a) of Regulation (EU) 2018/1725);

The basis for the processing is laid down by the following Union law: Article 11 of the consolidated European Treaty on the European Union states: “The institutions shall, by appropriate means, give citizens and representative associations the opportunity to make known and publicly exchange their views in all areas of Union action. The institutions shall maintain an open, transparent and regular dialogue with representative associations and civil society”.

Article 21(1) of the Treaty on European Union (TEU): overall mandate and guiding principles in the field of EU development cooperation; Articles 4(4) and 208 to 211 of the Treaty on the Functioning of the European Union (TFEU).

In addition, the processing is necessary for the fulfilment of the European Commission's obligation to ensure visibility of the Union’s financial support, as stipulated in recital 28, Article 46(2), (3) and (4) of Regulation (EU) 2021/947of the European Parliament and of the Council of 9 June 2021 establishing the Neighbourhood, Development and International Cooperation Instrument – Global Europe, amending and repealing Decision No 466/2014/EU and repealing Regulation (EU) 2017/1601 and Council Regulation (EC, Euratom) No 480/2009, OJ L 209, 14.6.2021

Where data are not marked as mandatory, the Data Controller processes your personal data based on your consent (Article 5 (d) of Regulation (EU) 2018/1725). All data processing is transparent and abiding by the principle of users’ opting-in/out, and allowing the data they provide to be used for specific purposes.

We do not process special categories of personal data (Article 10 of the Regulation (EU) 2018/1725.

  1. Which personal data do we collect and further process?

In order to carry out this processing operation the Data Controller collects the following categories of personal data (data marked with an asterisk ‘*’ are mandatory):

User Account Data (not publicly available)

Administrators of the site are the ones registering users in the system and activating users’ accounts. Therefore, they can view the username, which is always the e-mail address of the user through the back-end administration panel. Access to these details may be necessary to provide troubleshooting.

The password is never visible, and remains encrypted, even for those who manage the infrastructure and development of the platform.

The system collects additional data that is visible to administrators of the platform; this information includes:

This data provides an understanding of authenticated activity on the website, and allows the identification of inactive accounts. 

Project Data

The individuals’ personal data will be visible only to people who have accounts in EUDIGITOOL and will not become public to the country specific external websites.
 

  1. How long do we keep your personal data?

The Data Controller only keeps your personal data for the time necessary to fulfil the purpose of collection or further processing.

Personal data along with the user account will be kept on the site as long as the account is active and there was no request made by the user to remove him from the system. The account can be deleted by an email request that will be verified by the system administrators in coordination with DG NEAR.

Project related data will be kept for as long as the site operates as a tool of DG NEAR's promotion policy. Some parts of the data might be kept for a longer period where stipulated by financial authorities (10 years in case of financial transactions) or for auditing purposes (usually 7 years). Data will be automatically removed at the end of the respective period or when no longer needed.

  1. 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 either on the servers of the European Commission or of its contractors. All processing operations are carried out pursuant to the Commission Decision (EU, Euratom) 2017/46 of 10 January 2017 on the security of communication and information systems in the European Commission.

The Commission’s contractors are bound by a specific contractual clause for any processing operations of your data on behalf of the Commission, and by the confidentiality obligations deriving from the transposition of the General Data Protection Regulation in the EU Member States (‘GDPR’ Regulation (EU) 2016/679.]

In order to protect your personal data, the Commission has put in place a number of technical and organisational measures in place. 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 collected personal data and all information related are hosted on Vultr SSD servers, located in Frankfurt-am-Main, Germany. Photos and archive is stored in Amazon S3, also in Frankfurt-am-Main, Germany. Both providers are highly regulated. The contractor provides maintenance using highest security practices. Mailgun (also located in Frankfurt-am-Main, Germany) is also used as they process e-mail addresses.

Personal data in electronic form: access to your personal data, as well as any other information collected on the website is exclusively provided through an identification system with password, accessible to a restricted number of users, without prejudice of a possible future transmission of these data to the bodies charged with the control and inspection of the Commission's activities in conformity with EU law.

  1. Who has access to your personal data and to whom is it disclosed?

Access to your personal data is provided to the Commission staff responsible for carrying out this processing operation and to authorised staff according to the “need to know” principle. Such staff abide by statutory, and when required, additional confidentiality agreements.

Staff of OLAF, IDOC, IAS (Internal Audit Services), the Legal Service of the Commission as well as staff of other DGs (SG, DG BUDG and clearinghouse) upon request necessary in the context of official investigations or for audit purposes.

Pursuant to Article 3(13) of Regulation (EU) 2018/1725, public authorities (e.g. Court of Auditors, EU Court of Justice) which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients. The further processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.

Access to personal data is provided to external contractors working on behalf of and under contractual agreement with the Data Controller according to the “need to know” principle.

Information collected will not be given to any third party, except to the extent and for the purpose we may be required to do so by law.

  1. 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) on grounds relating to your particular situation.

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.

  1. 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, using the functional mailbox: NEAR-A1@ec.europa.eu

- 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.

  1. Where to find more detailed information?

The Commission Data Protection Officer (DPO) publishes the register of all processing operations on personal data by the 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-07086