1. Last update of this record: 02/04/2024

2. Reference number: 21/2020

Ref. Ares(2024)4404521

3. Name and contact details of the controller:

European Ombudsman (EO), 1 avenue du Président Robert Schuman, CS 30403, 67001 Strasbourg Cedex

Responsible department: Department for Administration -

Budget and Finance Team- e-mail: EOinvoice@ombudsman.europa.eu

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

Dpo-Euro-Ombudsman@ombudsman.europa.eu

5. Name and contact details of the processor:

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

European Commission -PMO services are responsible for the calculation of the salaries and equivalent payments of EO staff members by means of the New Pay Application "NAP"

Contact email: PMO-DATA-PROTECTION-COORDINATOR@ec.europa.eu

7. Purpose(s) of the processing:

The purpose is the calculation and payment of the salaries and equivalent payments (retirement pension, invalidity allowance, unemployment allowance and other benefits and allowances) to the EO staff members.

Short description of the processing:

The calculation of the remuneration and equivalent payments (retirement pension, invalidity allowance, unemployment allowance and other benefits and allowances) is done by PMO in the NAP system. The payments are made based on information related to the professional (ex: status, grade and step) and personal situation (ex: family benefits) of the person concerned processed in SYSPER by HR services. This information is then transcoded from SYSPER into NAP, which calculates the remuneration and equivalent financial benefits.

The identification of the staff member or former staff member in NAP is done via the “NUP”. This NUP is linked to the data encoded for the staff member by HR services or staff member in SYSPER. The link between the NUP and the data in SYSPER is the basis for the transcoding of the financial benefits as encoded in SYSPER into the NAP. The result of the calculation done via the NAP is reflected in the payslips.

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

- Categories of data subjects:

Staff members of the EO and former staff members (pensioners) to whom a payment is being made from the EO budget, whether officials, temporary or contract agents (“staff members”)

- Categories of data: all the data is processed in NAP

• name, surname and date of birth, NUP and personal number
• professional address and for former staff members, complete private address^[1]
• date of first entry into service^[2]
• identification of current employer
• professional situation (status, grade and step)
• Where payments need to be made to a third person or third party: identification of the third person or third party (name and surname, date of birth of the children.

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

Payslips and data concerning remuneration and equivalent payments are kept in the NAP 8 years after the extinction of all rights of the person concerned and of his/her dependants. Documents linked to attachment of remuneration and equivalent payments are kept in the NAP 7 years. They are deleted afterwards (see EC privacy statement on pay and financial benefits).

10. Recipients of the data:

The recipients are the EO, the Secretary General/the Director for Administration as authorising officers, the Head of Finances and Budget team, the staff members from Finances and Budget team responsible for the payslips management under the NAP and the PMO services in charge of the calculation of remuneration and equivalent payments.

11. Are there any transfers of personal data to third countries and/or to International Organisations? No

12. General description of security measures:

Only the staff member concerned, the Director for Administration, the Head of Finances services and the staff members from Finances services responsible for the payslips management under the NAP have access to the payslips.

The data is kept according to the security measures developed by the EC that owns the IT application NAP.

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

Staff members and former staff members have access to the data used for their personal identification and their professional situation via the payslip they receive. They can also ask to have access to relevant information concerning how the EO uses it. They can also request rectification of any incomplete or inaccurate data concerning them. 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 restrict its use.

At any time, they may ask the EO information concerning the processing of their personal data by e-mail (EOinvoice@ombudsman.europa.eu) or by contacting the Finances services. 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).

Privacy Statement relating to the payslips management in the European Ombudsman’s Office

Ref. Ares(2024)4404521

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 controller  is the European Commission (EC) - PMO services responsible for the calculation of the salaries of EO staff members by means of the New Pay Application ("NAP").

1. What personal data will the EO process?

All payments based on the EU Staff Regulations (EU) and the Conditions of Employment of Other Servants (CEOS) are processed via NAP.

NAP is used to process all payments for staff members of all EU institutions bodies and agencies. The PMO processes the payments of EO staff members, of active staff members of the EU institutions, bodies and agencies who have concluded a Service Level Agreement with the PMO[3], and the payments of all former staff members in receipt of a retirement pension, invalidity allowances or unemployment allowance.

We process the following personal data of staff members of the EO and former staff members (pensioners) to whom a payment is being made from the EO budget, whether officials, temporary or contract agents (“staff members”):

• name, surname and date of birth, NUP^[4] and personal number;
• professional address and for former staff members complete private address[5]
• date of first entry into service^[6];
• identification of current employer;
• professional situation (status, grade and step)

Where payments need to be made to a third person or third party (ex.: family benefits): identification of the third person or third party (ex: name and surname of the third party concerned, date of birth of the children).

2. Why does the EO process this personal data?

The purpose is the calculation and payment of the salaries and equivalent payments (retirement pension, invalidity allowance, unemployment allowance and other benefits and allowances) to the EO staff members.

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

The processing of the data is based on

• the Financial Regulation^[7] and its implementing rules;
• the Staff Regulations of Officials and the Conditions of Employment of Other Servants of the European Union^[8];
• Regulation No 260/68 of the Council of 29 February 1968 laying down the conditions and procedure for applying the tax for the benefit of the EU;
• Council Regulation (EU) 2016/300 of 29 February 2016 determining the emoluments of EU high-level public office holders.

Processing is necessary for the performance of a task carried out in the public interest (Article 5(1)(a) of Regulation 2018/1725) and for compliance with a legal obligation to which the controller is subject (article 5(1) (b) of Regulation 2018/1725).

4. Who is responsible for processing the data?

Data is processed by the Director for Administration, Finances and Budget team.

5. Who will be recipients of the data?

The recipients are the EO, the Secretary General/ the Director for Administration as authorising officers, the Head of Finances and Budget team, the staff members from the Finances and Budget team responsible for the payslips management under the NAP and the PMO services in charge of the calculation of remuneration and equivalent payments.

6. How long will the data be kept?

Payslips and data concerning remuneration and equivalent payments are kept in the NAP 8 years after the extinction of all rights of the person concerned and of his/her dependants Documents linked to attachment of remuneration and equivalent payments are kept in the NAP for 7 years.

Once the legal deadline has expired, the files are deleted.

7. How do we protect your data?

Only the staff member concerned, the Director for Administration, the Head of Finances and Budget team and the staff members of this team responsible for the payslips management under the NAP have access to the payslips. The data is kept according to the security measures developed by the EC that owns the IT application NAP.

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

You have access to the data used for your personal identification and professional situation via the payslip you receive. You can also ask to have access 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 management of payslips in the EO Office, at the following address:

European Ombudsman

1 avenue du Président Robert Schuman

CS 30403

F-67001 Strasbourg Cedex

EOinvoice@ombudsman.europa.eu

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: www.edps.europa.eu

 

 

[1] For former staff members, salary slips are to a large degree still being sent by regular mail;

[2]  This indicates whether rules pre- or post-reform 2004 or 2014 of the SR are applicable.

[3] Service Level Agreement signed between the EO and PMO on 26.02.2020

[4] The identification of the staff member or former staff member in the NAP is done via the “NUP”.

[5]  For former staff members, salary slips are to a large degree still being sent by regular mail

[6]  This indicates whether rules pre- or post-reform 2004 or 2014 of the Staff Regulations are applicable.

[7] Regulation (EU, Euratom) 2018/1046 of the European Parliament and of the Council  of 18 July 2018 on the financial rules applicable to the general budget of the Union.

[8] Regulation No 31 (EEC), 11 (EAEC), laying down the Staff Regulations of Officials and the Conditions of Employment of Other Servants of the European Economic Community and the European Atomic Energy Community.