EUROPEAN COMMISSION
PROTECTION OF YOUR PERSONAL DATA
Processing operation: Targeted consultation activities (including interviews, online Delphi
surveys, and focus groups)
Controller: European Commission, Directorate-General for Employment, Social Affairs and
Inclusion (DG EMPL)
Processor: Verian Group SA
Record reference: DPR-EC-01011
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.
This privacy statement concerns the processing operation interviews, online Delphi surveys, and
focus groups for the Study on Non take up of social benefits undertaken by the European
Commission, Directorate-General for Employment, Social Affairs and Inclusion (DG EMPL) as
presented below.
The data processor is Verian Group SA, established at Avenue des Arts 58, Brussels (BE), and its
external suppliers (CINT, Efficience3).
2. Why and how do we process your personal data?
Purpose of the processing operation: The Commission collects and uses your personal
information within the framework of targeted consultation activities to obtain your views on a
specific initiative, policy or intervention.
You are being contacted by Verian Group SA since the European Commission, Directorate-General
for Employment, Social Affairs and Inclusion (DG EMPL) has concluded that your views are
relevant and necessary to inform the Study on Non take up of social benefits concerned by the
targeted consultation.
Verian Group SA collected your contact details from the internet where they have been manifestly
made public by you or the organisation you work for. You have been identified by European
Commission, Directorate-General for Employment, Social Affairs and Inclusion (DG EMPL) as a
stakeholder whose views are relevant and necessary to achieve the specific purpose of the
targeted consultation activity in the public interest as described below. Your participation in the
targeted consultation activity is completely voluntary.
More specifically, the processing operation concerns the following processing activities and
purposes:
− to obtain the views of the respondents of a targeted consultation activity for the design,
evaluation and revision of policies, initiatives and interventions. To design, evaluate and
revise initiatives it is indispensable for the Commission to receive input and views from
those who are considered to be concerned by the policy, initiative or intervention.
− to obtain the views of stakeholders to explore a subject for which very limited information
is available. This exploratory targeted consultations activity (hereafter, 'targeted
consultation') will provide further information to the Commission necessary to take basic
conceptual decisions.
− The subject matter of the consultation activity require you to provide personal data in
your response that may identify or make you identifiable. These personal data will only
be published subject to your explicit consent.
− It is your responsibility if you opt for confidentiality of your personal data to avoid any
reference in your submission or contribution itself that would reveal your identity.
− The consultation activity uses the Commission's online questionnaire tool EUSurvey that
requires you to login via your ‘EU Login’ or ‘social media account’. ‘EU Login’ requires
certain personal data such as the name, surname and e-mail address of the registrant.
For further information, please refer to the privacy statements of ‘EU Login’ and ‘EU
Survey’ as well as the processing operations ‘Identity & Access Management Service
(IAMS)' (reference number in the public DPO register: DPR-EC-03187) and ‘EUSurvey’
(reference number: DPR-EC-01488). Should you choose to log in through your social
media account, please refer to the pertinent social media platform’s privacy statement.
− Your contribution to the targeted consultationis stored in the Commission’s document
management system (for further information on the Commission’s document
management system please refer to the processing operation ‘Management and (short-
and medium-term) preservation of Commission documents`, reference number: DPR-EC-
00536).
The personal data processed may be reused for the purpose of procedures before the EU Courts,
national courts, the European Ombudsman or the European Court of Auditor.
Your personal data will not be used for automated decision-making including profiling.
3. On what legal ground(s) do we process your personal data
We process your personal data, because:
(a) processing is necessary for the performance of a task carried out in the public interest;
(c) it is based on your consent, for one or more specified purposes:
− If the subject matter of a targeted consultation requires respondents to provide personal
data in their response that make the data subject identifiable, their publication;
− to be contacted by the Commission for the present consultation
The Union law which is the basis for the processing based on Article 5(1)(a) of Regulation (EU)
2018/1725 is the Treaty of the European Union, and more specifically its Articles 1 and 11, Article
298 of the Treaty on the Functioning of the European Union, read in conjunction with Recital 22
of Regulation (EU) 2018/1725), as well as the Protocol 2 on the application of the principles of
subsidiarity and proportionality.
4. Which personal data do we collect and further process?
In order to carry out this processing operation Verian Group SA collects the following categories
of personal data
• name and surname,
• profession,
• country of residence,
• e-mail address of the respondent,
• the name of a self-employed individual (natural persons) on whose behalf the respondent
is contributing,
• personal data related to the physical, economic, cultural, or social identity of the
respondent, insofar as they are not falling under Article 10 of the Regulation,
• personal data included in the response or contribution to the targeted consultation
activity, including (personal) opinions (if the targeted consultation at hand requires so),
Furthermore, you may spontaneously provide other, non-requested personal data in the context
of your reply to the targeted consultation.
Please note that the Data Controller does not request nor expect that data subjects provide any
special categories of data under Article 10(1) of Regulation 2018/1725 (that is “personal data
revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union
membership, and the processing of genetic data, biometric data for the purpose of uniquely
identifying a natural person, data concerning health or data concerning a natural person’s sex life
or sexual orientation”) related to themselves or to third persons in their contributions to the
targeted consultation activity. Any spontaneous inclusion of these types of personal data is the
responsibility of the data subject and by including any of these types of data the data subject is
considered to provide his/her explicit consent to the processing, in accordance with Article
10(2)(a) of Regulation 2018/1725.
5. 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, namely for a maximum of five years after the closure of the file
to which the present targeted consultation belongs. A file is closed at the latest once there has
been a final outcome in relation to the initiative to which the targeted consultation contributed.
This administrative retention period of five years is based on the retention policy of European
Commission documents and files (and the personal data contained in them), governed by the
common Commission-level retention list for European Commission files SEC(2019)900. It is a
regulatory document in the form of a retention schedule that establishes the retention periods
for different types of European Commission files. That list has been notified to the European Data
Protection Supervisor.
The administrative retention period is the period during which the Commission departments are
required to keep a file depending on its usefulness for administrative purposes and the relevant
statutory and legal obligations. This period begins to run from the time when the file is closed.
In accordance with the common Commission-level retention list, after the ‘administrative
retention period’, files including (the outcome of) targeted consultations (and the personal data
contained in them) can be transferred to the Historical Archives of the European Commission for
historical purposes (for the processing operations concerning the Historical Archives, please see
record of processing 'Management and long-term preservation of the European Commission's
Archives’, registered under reference number DPR-EC-00837).
6. 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 on the servers of the Commission. All processing operations are carried out
pursuant to Commission Decision (EU, Euratom) 2017/46 of 10 January 2017 on the security of
communication and information systems in the Commission.
In order to protect your personal data, the Commission has put in place a number of technical
and organisational measures. 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.
7. 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, in
particular to follow-up on the targeted consultation. Such staff abide by statutory, and when
required, additional confidentiality agreements.
The information we collect 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.
8. 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. Under certain conditions, 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.
Insofar you have consented to the certain processing of your personal data to the Data Controller
for the present processing operation, you can withdraw your consent at any time by notifying the
Data Controller. The withdrawal will not affect the lawfulness of the processing carried out before
you have withdrawn the consent.
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.
In accordance with Article 14(3) of Regulation (EU) 2018/1725, your request as a data subject will
be handled within one month of receipt of the request. That period may be extended by two
further months where necessary, taking into account the complexity and number of the requests.
In such case you will be informed of the extension of the time limit, together with the reasons for
the delay.
9. 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.
European Commission, Directorate-General for Employment, Social Affairs and Inclusion (DG
EMPL) at
[email protected]
- The Data Protection Officer (DPO) of the Commission
You may contact the Data Protection Officer (
[email protected])) 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 (
[email protected]) 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.
10. 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-01011.
Saatja: Verian Takeup <
[email protected]>
Saaja:
[email protected], Konstantin Koch, SKA Info
Teema: Request to interview - EU Commission Study on non take up of social benefits
Tähelepanu! Tegemist on väljastpoolt asutust saabunud kirjaga. Tundmatu saatja korral palume linke ja faile mitte avada.
Dear Irje Tammeleht,
My name is Konstantin Koch, I work at Verian<https://www.veriangroup.com/en-be/>, an independent policy research company. We have been commissioned by the European Commission, Directorate-General for Employment, Social Affairs and Inclusion (DG EMPL) to work on a study on the issue of non-take up of social benefits. Please see the endorsement letter attached.
Our research so far has focused on identifying which factors may lead to non take up of social benefits in different Member States of the EU, through an online survey with potential beneficiaries and a first round of consultations with experts.
I am reaching out because we would like to conduct an interview with you as part of the next phase of the study. Building on the research conducted so far, we aim to explore in more depth why and how the barriers to non take-up emerge in practice.
If you are interested in participating, we would be grateful if you could let us know your availability.
We also attach a privacy notice explaining how personal data and contributions will be treated as part of this project.
If you believe that a colleague within your organisation would be a more suitable participant, please feel free to forward them this invitation or share their contact details with us.
Thank you very much for considering this invitation and please feel free to reach out if you have any questions. We look forward to hearing from you.
Kind regards,
Konstantin Koch
[A black and orange logo Description automatically generated]
Konstantin Koch
Research Executive – Policy Evaluation, Behaviour Change, and Communication
Avenue des Arts 58, 1000 Brussels, Belgium
veriangroup.com<https://www.veriangroup.com/>
References to "Verian" and to the "Verian Group" are to Project Pearl Holdco Limited (registered in England and Wales with number 14041889) and its subsidiary undertakings (as that expression is defined in the Companies Act 2006) from time to time. The registered office of Project Pearl Holdco Limited is 4 Millbank, London, SW1P 3JA, England.
This email is for the information of the addressee only and should not be reproduced and/or distributed to any other person. It is confidential and may contain copyright material of members of the Verian Group of companies. Opinions and views expressed in this message may not necessarily reflect the opinions and views of the Verian Group. If you are not the intended recipient, please notify us immediately and delete all copies of this message. It is your responsibility to scan this message for viruses.
EUROPEAN COMMISSION
DIRECTORATE-GENERAL FOR EMPLOYMENT, SOCIAL AFFAIRS AND INCLUSION
Social Rights and Inclusion
Social Policies, Child Guarantee, SPC
Brussels
EMPL.D.1/BL
Dear Sir, / Dear Madam,
The Directorate-General for Employment, Social Affairs and Inclusion (DG EMPL) has
constructed a Verian Group (lead), in cooperation with Sapienza University of Rome and
the Odenore (Observatory of Non-take up of Rights and Services), to conduct a study on
the non-take up of social benefits in the EU Member States.
The aim of this study is to explore the rate of non-take up of social benefits in the EU,
identify the underlying causes and propose potential solutions. As part of the project, the
contractor will consult with experts in line ministries in charge of social policy, public
welfare services as well as organisations that represent or provide services to individuals
at risk of poverty or social exclusion, and who may be eligible for social benefits in the
Member States.
You are invited to contribute to this study with your valuable expertise and insights by
taking part in consultation activities, including interviews and focus groups. Your
participation is voluntary, and contributions to the study will be anonymised before the
publication of project reports.
The action covers all EU Member States and will take place throughout 2025 and the first
half of 2026.
If you wish to receive further clarification about the scope or context of this action, you
can contact the Unit D.1, Social Policies, Child Guarantee, SPC of the Directorate-General
for Employment, Social Affairs and Inclusion (DG EMPL):
[email protected].
Additionally, you can reach out to the project’s core team members if you need additional
information:
• Patricia Scherer, Director for Policy Implementation, Verian Group
[email protected]
• Margherita Neri, Associate Director, Verian Group
[email protected]
Thank you in advance for your kind cooperation and valuable contribution to this project.
Yours faithfully,
Qualified electronic signature by:
JIŘÍ ŠVARC
Date: 2025-02-09 20:11:50 +01:00
Jiri Svarc
Head of Unit
Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË – Tel. +32 22991111