Study Supporting the Evaluation of the PIF Directive Interview Guides for EU IBOAs This interview is part of a study commissioned by the European Commission to support the evaluation of Directive (EU) 2017/1371 on the fight against fraud to the Union’s financial interests by means of criminal law (the “PIF Directive”). The evaluation aims to assess the effectiveness, efficiency, relevance, coherence, and EU added value of the Directive. To support this, the Commission has tasked an external consortium led by the Centre for Strategy & Evaluation Services (CSES), in partnership with Asterisk Research & Analysis, Spark Legal and Policy Consulting, and Tetra Tech International Development, with conducting an independent evidence-gathering study. The evaluation covers the period from the deadline for transposition by the Member States ( 6 July 2019) until 2025. Your participation in this interview is voluntary and your responses will be treated in strict confidence. No individuals will be identified in any published report or analysis. The data collected will be used exclusively for the purposes of this evaluation and in line with applicable data protection rules. We will share the full privacy notice describing how your personal data will be handled. We greatly appreciate your time and expertise . Opening perspective and role Could you briefly describe your role and your organisation’s/network’s relevance to offences affecting the Union’s financial interests? From your perspective, which aspects of the PIF Directive are most relevant to your work or to the experience of your members (e.g., cross-border cooperation, corruption, money laundering, financial intelligence, asset recovery, or coherence with other legal frameworks ) ? Implementation & Effectiveness Practical experience and cross-border cooperation From your perspective, to what extent has the PIF Directive improved cross-border cooperation in cases involving fraud, corruption, money laundering, or other offences affecting the Union’s financial interests? Have you observed any practical obstacles in cross-border cooperation or information exchange that appear linked to differences in legal definitions, thresholds, procedures, or institutional mandates ? From your perspective, has the EU framework in this area made any practical advantages to cross-border cooperation? If so, in what ways? Scope, operational gaps and emerging risks In your experience, does the current scope of the PIF Directive capture the main types of offences that are relevant today in protecting the Union’s financial interests? Have you observed any practical gaps or grey areas that make detection, coordination, or follow-up more difficult across borders? Asset tracing, recovery and financial follow-up Have you observed recurring barriers to effective asset recovery in cross-border cases, for example linked to legal thresholds, differences in national procedures, access to information, or coordination between authorities? Where relevant, are there particular challenges in linking financial intelligence, criminal investigation, and recovery processes across jurisdictions? Relevance How well does the PIF Directive respond to current and emerging risks affecting the Union’s financial interests, including digitally enabled fraud, online schemes, crypto-assets, and links with organised crime? Are there any provisions that now appear outdated, insufficient, or missing in light of recent developments in international cooperation or financial crime patterns? Coherence with international and EU frameworks From an international cooperation perspective, could you give feedback on the inclusion of corruption – bribery and misappropriation – in the PIF Directive, including gaps , overlaps and inconsistencies you have identified in the current framework relative to EU and international anti-corruption standards? In your opinion, how well does the PIF Directive align with the international instruments, standards, and cooperation frameworks that your organisation or network works with in practice? From an international cooperation perspective, h ow well does the PIF Directive work alongside instruments establishing relevant EU anti-fraud bodies, in particular the EPPO, OLAF, Eurojust, and Europol? Are there areas where inconsistencies or gaps in concepts, definitions, or thresholds between the PIF Directive and these instruments create difficulties in practice? Efficiency From your perspective, are there particular information-sharing, intelligence, or data-related issues that affect the practical protection of the Union’s financial interests across borders? What, if anything, would improve the practical use, comparability, or exchange of information relevant to offences affecting the Union’s financial interests? EU added value From your perspective, what added value, if any, does the PIF Directive bring in comparison with relying solely on national legal frameworks or broader international cooperation arrangements? Are there areas where that added value has been more limited than expected? Final thoughts Is there anything else you would like to share to inform this evaluation, especially in terms of lessons learned, best practices, or systemic improvements? Many thanks for your time! The information and views set out in this interview guide are those of the author(s) and do not necessarily reflect the official opinion of the Contracting Authority (i.e. the Commission). This interview guide is a tool to gather data for a study supporting the European Commission's evaluation of the PIF Directive . While every effort is made to ensure the accuracy of the data included in the final study report, the Contracting Authority does not guarantee the accuracy of raw data collected during interviews. Neither the Contracting Authority nor any person acting on the Contracting Authority’s behalf may be held responsible for the use which may be made of the information contained in the final study report. These interview guides are used by CSES for the sake of the present assignment solely and as such they do not bind or reflect, in any way, the opinion of the European Commission or of its services.
EUROPEAN COMMISSION PROTECTION OF YOUR PERSONAL DATA This is a specific privacy statement that provides information about the processing and the protection of your personal data through targeted consultation activities (including stakeholder interviews) of the European Commission. Processing operation: Targeted consultation activities ( stakeholder interviews) concerning the supporting study the Evaluation of the implementation and impact of Regulation (EU) 2017/1939 of 12 October 2017 on the European Public Prosecutor’s Office (EPPO), and of the effectiveness and efficiency of the EPPO and its working practices and the evaluation of Directive (EU) 2017/1371 Data Controller: European Commission , Directorate-General for Justice and Consumers, Unit A.4 – Criminal Justice Data Processor: Consortium of organisations led by the Centre for Strategy and Evaluation Services (CSES Europe), 104 Lower Baggot Street Dublin 2, Ireland . Record reference: DPR-EC-01011 Table of Contents Introduction Why and how do we process your personal data? On what legal ground(s) do we process your personal data? Which personal data do we collect and further process? How long do we keep your personal data? How do we protect and safeguard your personal data? Who has access to your personal data and to whom is it disclosed? What are your rights and how can you exercise them? Contact information Where to find more detailed information ? Introduction The European Commission (hereafter ‘the Commission’) is committed to protecting your personal data and respecting 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. The information in relation to the processing of personal data linked to the processing operation ‘Targeted consultation activities’, undertaken by the European Commission ( DG JUST Directorate A ) and CSES Europe , is presented below. 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 ( stakeholder interviews) that form part of Study to support the Evaluation of the implementation and impact of Regulation (EU) 2017/1939 of 12 October 2017 on the European Public Prosecutor’s Office (EPPO) and of the effectiveness and efficiency of the EPPO and its working practices and the evaluation of Directive (EU) 2017/1371 . More specifically, this concerns processing activities related to the following targeted consultation activities: a semi-structured stakeholder interview programme . In view of the design, evaluation and revision of initiatives, it is indispensable for the Commission to receive input and views from those who are considered to be concerned by the policy or initiative. You are being contacted by CSES Europe or its partner organisations (Asterisk Research & Analysis, Spark Legal & Policy Consulting, Tetra Tech International Development) on behalf of DG JUST Directorate A , Unit A.4 since it has been concluded that your views are relevant and necessary to inform study to the support study and subsequent e valuation of the PIF Directive. Your contact details have been gathered in one of the following ways: the contact details of the prospective respondent are already in the possession of/processed by the controller/processor , and their further processing for the targeted consultation activity is lawful . the contact details of the prospective respondent have not been in the possession of the controller/processor and have been solely collected for th is targeted consultation activity . Contact details have been obtained either from publicly available sources, or through intermediaries with the explicit consent of the data subject . The subject matter of the consultation activities may require you to provide some basic background personal data in your response (e.g. name, organisation , type of stakeholder). These personal data will only be published based on your explicit consent. It is your responsibility, if you opt for the confidentiality of your personal data, to avoid any reference in your submission or contribution (including free text fields or uploaded documents) that would reveal your identity. C onsultation activities (semi-structured stakeholder interviews) may be recorded to facilitate full coverage and ensure accurate reflection of the discussion in subsequent work . However, they will only be recorded based on the explicit consent of all participants. 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 Auditors . Your personal data will not be used for automated decision- making, including profiling. 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 . The Union law which is the basis for the processing based on Article 5(1)(a) and (b) 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. Which personal data do we collect and further process ? In order to carr y out this processing operation , the following categories of personal data may be processed: name and surname, profession, country of residence, e-mail address of the respondent, 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. 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(20 25 ) 6 00 . 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 Histo rical Archives, please see record of processing 'Management and long-term preservation of the European Commission's Archives’, registered under reference number DPR-EC-00837 ). How do we protect and safeguard your personal data? All personal data in electronic format (e-mails , documents, databases, uploaded batches of data, etc.) is stored on the servers of the Commission and of the contractors (processors ) . All pr ocessing 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. Access to your personal data is provided to the Commission’s contractor responsible for carrying out the evaluation and to authorised staff according to the “need to know” principle. The contractors are bound by a specific contractual clause for any processing operations of your personal data on behalf of the Commission. The processors have to put in place appropriate technical and organisational measures to ensure the level of security required by the Commission. 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 this study and associated evaluation , to the Commission’s contractor responsible for carrying out the study , 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. Transfers of personal data outside of the EU or the EEA are likely to occur in the context of the evaluations, for the Commission to carry out its tasks and to comply with its obligations under the applicable legislation and to the financing agreements with the partner/beneficiary countries. Potential transfers of personal data to the partner/beneficiary countries take place on the basis of derogations set out in Regulation (EU) 2018/1725, namely for an important reason of public interest (Article 50(1)(d)). Such public interest is outlined in Articles 1 and 11 of the Treaty on European Union as well as in Article 298 of the Treaty on the Functioning of the European Union. In particular, processing of personal data by the processor may qualify as an international transfer when the contractor is a non-EU/EEA entity or a non-EU /EEA subcontractor. Please note that pursuant to Article 3(13) of Regulation (EU) 2018/1725 , public authorities (e.g. Court of Auditors, EU Court of Justice) which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing. 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. 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 it in case your personal data is 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 as y ou 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 a case, you will be informed of the extension of the time limit, together with the reasons for the delay . 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 Justice and Consumers , Unit A.4 – Criminal Justice 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. 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:
[email protected]
Teema: Request for input from the European Commission questionnaire on the PIF Directive (deadline 8 May 2026)
Kuupäev: 2026-04-28 20:55
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Dear EPAC/EACN Members and Observers,
We would like to inform you that the EPAC/EACN Secretariat has received an
invitation from the European Commission’s contractor (Spark Legal and Policy
Consulting) to contribute to the evaluation of the Directive (EU) 2017/1371
on the fight against fraud to the Union’s financial interests (the “PIF
Directive”).
Following our exchange with the Commission, we agreed to collect written
input from our network members. In this regard, we kindly invite you to
contribute by responding to the attached questionnaire.
We would highly appreciate receiving your input by 8 May 2026 (inclusive).
Please find attached the questionnaire. Kindly note that:
* Certain questions have been highlighted by the Commission as priority
areas, and your input on these would be particularly valuable;
* If you are unable to respond to some of the highlighted questions, you may
simply indicate this;
* You are also very welcome to provide input on any other questions you
consider relevant.
Your contributions will help ensure that the EPAC/EACN network provides
meaningful, practice-based insights reflecting national experiences and
perspectives.
Please note that participation is voluntary and that all contributions will
be treated in line with the applicable confidentiality and data protection
requirements outlined in the attached materials.
Should you have any questions or require further clarification, please do
not hesitate to contact the Secretariat.
We sincerely appreciate your time and contribution.
Kind regards,
The EPAC/EACN Secretariat
_____________________________________
EPAC/EACN Secretariat
Special Investigation Service
of the Republic of Lithuania
A. Jakšto g. 6, 01105 Vilnius
@: <mailto:
[email protected]>
[email protected]
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