The ECB intends to use an external contractor to monitor and track discussions about ECB related topics on different social media channels. On 21 March 2018, we adopted an Opinion on the processing of personal data for social media monitoring at the European Central Bank (ECB). As participants were not able to register for this conference unless they gave their consent to share personal information with the host Member State authorities, their consent was not freely given and so consent cannot, in this case, be considered a valid legal basis for the transfer of data. To qualify as a valid legal basis for the transfer of data, consent must be freely given. We also responded to concerns about the transfer of the personal data collected to the authorities of the host Member State, based on the premise that participants had consented to this. We therefore concluded that requesting scanned copies of participant ID in this case was disproportionate and not in compliance with the legal requirements laid out in Regulation 45/2001. The EU institution also failed to formally notify their Data Protection Officer (DPO) of the collection of scanned copies of individuals’ ID, as is required under Regulation 45/2001, which sets out the data protection rules for the EU institutions. Moreover, in certain Member States, it is illegal to photocopy passports unless justified by the law. For example, checking passports or ID cards at the entrance to the conference and comparing them with the information submitted online. In our investigation, we found that the EU institution could have used a less intrusive means of verifying the identity of participants. ![]() The EDPS received a complaint relating to this requirement, to which we responded on 10 April 2018. As the precise implications of this for the rights and freedoms of individuals require more clarity, wider debate on the future of information exchange in the EU, the governance of interoperable databases and the safeguarding of fundamental rights is needed.”Īs part of the registration process for an international conference organised by one of the EU institutions, individuals were required to submit a scanned copy of their passport or identity card, in order to verify their identity. ![]() However, in their current form, the Commission’s Proposals would alter the structure and operation of the EU’s existing IT databases and change the way in which fundamental legal principles in this area have traditionally been interpreted. Interoperability, implemented in a well-considered manner and in full compliance with fundamental rights, could prove useful in facilitating this. ![]() Giovanni Buttarelli, EDPS, said: “ Competent authorities across the EU must be able to share information in order to manage current migratory challenges and terrorist and crime-related issues. The Opinion follows a reflection paper published by the EDPS on interoperability on 17 November 2017. Interoperability, the process of enabling large-scale EU databases to communicate and exchange information, might prove a useful tool, but it is also likely to have profound legal and societal consequences, the EDPS said on 16 April 2018, as he published his Opinion on the Proposals for two Regulations establishing a framework for interoperability between EU large-scale information systems. The EU needs a smarter approach to information sharing in order to address challenges relating to security and border management. EDPS Brochure: Shaping a Safer Digital Future.
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