1. Last update of this record: 15/11/2023

2. Reference number: 17/2020

Ref. Ares(2024)1309590 - 20/02/2024

3. Name and contact details of the controller

European Ombudsman, 1 avenue du Président Robert Schuman, CS 30403, F-67001 Strasbourg Cedex -

Contact: Directorate for Administration- HR Team - EO@ombudsman.europa.eu

Responsible department: -HR Team

4. Name and contact details of the Data Protection Officer:

Ms Francesca Pavesi

Deputy DPO: Mr Nicholas Hernanz

Functional mailbox: Dpo-Euro-Ombudsman@ombudsman.europa.eu

5. Name and contact details of the processor: N/A

6. Name and contact details of the joint controller(s)

- European Parliament (EP) - DG “Personnel”- “Staff Front Office Unit”- that deals with the requests for special cards for the staff members assigned in the Brussels Office -

Contact: PERS-PrivilegesBru@europarl.europa.eu.

-French and Belgian national authorities, which issue the special cards.

• Contact for the French national authorities (French Ministry of Foreign Affairs): email: Thomas.Anin@diplomatie.gouv.fr
• For the Belgian national authorities: Service Public Fédéral Affaires Étrangères- tel : :+32 (0)2 501 81 11

7. Purpose(s) of the processing:

Requesting special cards from the French or Belgian Ministry of Foreign Affairs for newly recruited staff members and their family members.

Short description of the processing:

Civil servants working for a European body and seconded national experts, have the right to ‘simplified residence’, which amounts to the issue of a ‘special identity card’ issued by the Foreign Affairs Ministry and not by the municipal authority. The members of their family can also take advantage of this system unless they are working in Belgium/France. Holders of these special cards must not register in the municipality of residence. They are however included in a separate local authority register and receive a national number (though this does not appear on their special identity card). 

Newly recruited staff member who fulfil the requirements, can request a special ID for themselves and their family (children and spouse) by filing a request directly to HR team. The HR Team (HR assistant) contacts the relevant public authority of the country where the office is located (France or Belgium) to issue a special card (“attestation de fonctions” for France or “special identity card” for Belgium).

- For the special cards delivered by the French Ministry of Foreign Affairs, the HR assistant uses a specific form and encloses supporting documents (copy of passports or ID cards). The special cards are valid for 4 years, after which the relevant staff member may ask for a renewal to the French Ministry of Foreign Affairs. In December each year, the HR assistant sends to the French Ministry an Excel Table (no 1) with the list of staff members in service having requested a special card from France for the relevant year. When the staff member leaves the institution, the HR assistant sends back the relevant special cards to the French public authority and keeps a proof of the sending back in electronic version.

- For the special cards delivered by the Belgian Ministry of Foreign Affairs, the newly recruited staff members contact directly the EP- DG Personnel- Staff Front Office Unit (PERS-PrivilegesBru@europarl.europa.eu), who deals with the requests for the special cards and sends them to the Belgian Federal Service Public of Foreign Affairs. The Director for Administration then signs the requests. The special identity cards are valid for 5 years.

8. Description of the categories of data subjects and of the categories of personal data:

- Data subjects:

Staff members of the EO Office (officials, temporary and contract agents), their family members if applicable (spouse and/or children),

- Categories of personal data:

• data on the form used for requesting the special cards:

- concerning the EO staff member: name, surname; date and place of birth; nationality; family situation; function and grade; home address;

- concerning the spouse and children of the EO staff member: name, surname; date and place of birth; nationality;

• supporting documents to the request: copy of the passport or ID card of the EO staff member and family members for which a special card is requested;
• data on the Excel table (no 1) sent to the French Ministry of Foreign Affairs: data mentioned above concerning the EO staff member; special card number; date of arrival in France; date of exercise of functions; date of end of validity of the special card.

The HR assistant further processes an Excel table (no 2) for managing internally the requests for special cards with the following data: name, surname, number of the card and the date of validity.

9. Time limit for keeping the data and, where possible, for erasure:

Supporting documents collected by the EO for requesting the special cards are deleted as soon as the special cards are issued. The data on the Excel table (no 1) sent to the French Ministry of Foreign Affairs is deleted one month after having sent it.

The data on the Excel table (2) used for managing internally the requests for special cards is kept for 5 years after the cancellation of the last special card and updated during the process. Once a staff member leaves the Office, the relevant data is deleted.

10. Recipients of the data:

The EO, the Secretary General, the Director for Administration, the Head of HR team, the staff member in the HR team in charge of dealing with the special cards, the EP relevant services (DG Personnel- Staff Front Office Unit), the French and Belgian Ministries of Foreign Affairs.

11. Are there any transfers of personal data to third countries and/or to International Organisations? : N/A

12. General description of security measures:

Supporting documents used for requesting special cards are kept in electronic version in the Directorate for Administration, HR team, in a shared network.

Access is only authorised to the Director for Administration and the HR assistant in charge of dealing with the special cards. 

13. Information on how data subjects can exercise their rights of access and rectification, and where applicable, of erasure, restriction and data portability:

The data subjects have the right of access to their own personal data and to relevant information concerning how the EO uses them. They have also a right to request rectification of any incomplete or inaccurate data concerning them. They can rectify identification data at any time during the procedure. They have a right to object to the use of their data by the EO on grounds relating to their particular situation, at any time. Under certain conditions, they have the right to ask that the EO deletes their personal data or restricts its use.

At any time, they may ask the EO information concerning its processing of their personal data by e-mail (EO@ombudsman.europa.eu) or by contacting the Directorate for Administration, HR team.

Data subjects can also ask information concerning the processing of their personal data to the European Parliament (EP) - DG “Personnel”- “Staff Front Office Unit”- by email (PERS-PrivilegesBru@europarl.europa.eu) and/or to the French Ministry of Foreign Affairs (Thomas.Anin@diplomatie.gouv.fr) and to the Belgian Federal Service Public of Foreign Affairs tel : :+32 (0)2 501 81 11

The EO will reply to their requests as soon as possible and within one month at the latest. They may also contact the EO Data Protection Officer at: dpo-euro-ombudsman@ombudsman.europa.eu If they wish to complain about the Ombudsman’s handling of their personal data, they may contact the European Data Protection Supervisor (www.edps.europa.eu) at the following address: EDPS@edps.europa.eu

Privacy Statement relating to the residence permits of EO staff members (special cards)

Ref. Ares(2024)1309590 - 20/02/2024

This privacy statement explains the reason for the processing, the way the European Ombudsman (EO) collects, handles and ensures protection of all personal data provided, how that information is used and what rights the data subjects may exercise in relation to their data.

The controller is the EO. The joint controllers are (i) the European Parliament (EP) - DG Personnel- Staff Front Office Unit- that deals with the requests for special cards for the staff members assigned in the Brussels Office and (ii) the French and Belgian national authorities which issue the relevant special cards.

1. What personal data will the European Ombudsman process?

We process personal data of the EO staff members (officials, temporary and contract agents), and their family members if applicable (spouse and children) who request a special card. The personal data we process includes the names, surnames, identification details (passport or ID, nationality, etc) and dates of validity, among others.

2. Why does the European Ombudsman process these personal data?

The purpose is to request special cards from the French or Belgium Ministry of Foreign Affairs for newly recruited staff members and their family members who so wish.

3. What are the legal bases and necessity for processing this data?

We process your personal data on the basis of Article 5(1)(a) (the performance of a task carried out in the public interest) and 5 (1)(b) (compliance with a legal obligation to which the controller is subject) of Regulation 2018/1725.

The legal basis is Article 11(b) of the Protocol (No 7) on the privileges and immunities of the European Union, which lays down that officials and other servants of the Union shall, together with their spouses and dependent members of their families, not be subject to immigration restrictions or to formalities for the registration of aliens.

4. Who is responsible for processing the data?

The Ombudsman’s Directorate for Administration - HR team.

5. Who will be recipients of the data?

The EO, the Secretary General, the Director for Administration, the Head of HR team, the staff member of the HR Team in charge of dealing with the special cards, the EP relevant services (DG Personnel- “Staff Front Office” Unit) and the French and Belgian Ministries of Foreign Affairs.

6. How long will the data be kept?

Supporting documents collected by the EO for requesting the special cards are deleted as soon as the special cards are issued. The data on the Excel table sent to the French Ministry of Foreign Affairs is deleted one month after having sent it.

The data on the Excel table used for managing internally the requests for special cards is kept for 5 years after the cancellation of the last special card and updated during the process. Once a staff member leaves the Office, the relevant data is deleted.

7. How do we protect your data?

Supporting documents used for requesting special cards are kept in electronic version in the Directorate for Administration-HR team in a shared network.

Access is only authorised to specific users in the HR team.

Data stored on the EO servers is protected by numerous security measures set up by the ICT sector to protect the integrity and confidentiality of the Institution's electronic property.

8. What are your rights and how can you exercise them?

You have the right of access to your own personal data and to relevant information concerning how the EO uses it.

You have also a right to request rectification of any incomplete or inaccurate data concerning you. You can rectify identification data at any time. You have a right to object to the use of your data by the EO on grounds relating to your particular situation, at any time. Under certain conditions, you have the right to ask that the EO deletes your personal data or restrict its use.

The EO will reply to your requests as soon as possible and within one month at the latest.

9. Who to contact in case of queries or complaints concerning data protection issues?

At any time, you may send data protection related questions concerning the procedure for requesting special cards to the EO, at the following address:

European Ombudsman

Directorate for Administration- HR Team

1 avenue du Président Robert Schuman

CS 30403

F-67001 Strasbourg Cedex

EO@ombudsman.europa.eu

You also may contact the European Parliament (EP) - DG “Personnel”- “Staff Front Office Unit”- that deals with the requests for special cards for the staff members assigned in the Brussels Office (mail: PERS-PrivilegesBru@europarl.europa.eu) and/or the French and Belgian national authorities, which issue the special cards.

• French Ministry of Foreign Affairs: email: Thomas.Anin@diplomatie.gouv.fr

• Service Public Fédéral Affaires Étrangères- tél : +32 (0)2 501 81 11

You also may contact the Data Protection Officer of the EO office at the following address: DPO-Euro-Ombudsman@ombudsman.europa.eu

You may lodge a complaint with the European Data Protection Supervisor at any time at the following address: EDPS@edps.europa.eu