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The complainants, a group of civil society organisations, were concerned that the European Commission did not assess human rights risks before providing support to African countries to develop surveillance capabilities, notably in the context of the EU Emergency Trust Fund for Africa (EUTFA). The complainants contended that, before agreeing to support projects with potential surveillance implications, such as biometric databases or mobile phone monitoring technologies, the Commission should have carried out prior risk and impact assessments to ensure that the projects do not result in violations of human rights (such as the right to privacy).

Based on the inquiry, the Ombudsman concluded that the measures in place were not sufficient to ensure the human rights impact of EUFTA projects was properly assessed. To address the shortcomings she identified, the Ombudsman made a suggestion for improvement to ensure that, for future EU Trust Fund projects, there is a prior human rights impact assessment.