Privacy statement (pilot)

Draft for review. Items marked [TO CONFIRM] are open and listed at the end.

This statement explains what personal data the audience engagement tool handles during its pilot, why, and what your rights are. The tool lets Commission staff run live polls, quizzes, surveys and audience Q&A in meetings and events. The pilot is used in real internal Commission meetings.

The Commission processes personal data under Regulation (EU) 2018/1725.

1. Who is responsible

The data controller is:

Stefan Happer, Head of Sector HR.C4.003
Learning and Development
European Commission
stefan.happer@ec.europa.eu

2. Why we process your data

We process data to let participants answer polls and ask questions in a meeting, to show the results to the meeting, and to let organisers sign in and manage their sessions. We do not use the data for any other purpose. We do not use analytics, advertising or tracking.

Taking part is voluntary. You can attend a meeting without answering any poll or asking any question.

Legal basis: Article 5(1)(a) of Regulation (EU) 2018/1725, processing necessary for the management and functioning of the institution. [TO CONFIRM]

3. What we collect

If you take part in a session

You do not need an account, and we do not ask for your name or email address. We do not store your IP address or device details with your answers.

If you are an organiser, co-organiser or administrator

Technical logs

The hosting provider keeps technical logs, which include IP addresses, for one hour, to run and secure the site. These logs are not linked to answers or questions.

4. What the organiser can see

Your answers are anonymous to the organiser. Organisers see totals and results for polls, quizzes and surveys, the text of open answers, and the text of questions. They see a name only if you add a display name to a question. They never see your browser identifier.

Please keep two things in mind:

Organisers can download results and questions as a file. Display names are left out of these files by default. Once downloaded, a file is the organiser’s responsibility.

5. How long we keep it

6. Where the data is and who can access it

During the pilot, the tool is hosted by Vercel (website) and Neon (database), in data centres in the European Union. Sign-in emails are sent through Brevo. These companies act on our instructions and may not use the data for their own purposes.

Vercel and Neon are companies headquartered in the United States. [TO CONFIRM: transfer safeguards, for example certification under the EU-US Data Privacy Framework]

Access is limited to:

After the pilot, the tool is planned to move to Commission cloud services based in Europe. This statement will be updated then.

7. How we protect it

Data is encrypted in transit and at rest. Organisers sign in with single-use links sent to approved email addresses. Join links and codes are kept out of logs. Private content, such as questions waiting for approval, is never sent to participants’ devices.

8. Your rights

You can ask to access, correct or delete your data, to restrict its processing, or to object to it. Write to stefan.happer@ec.europa.eu.

Because answers are not linked to your identity, we usually cannot find your individual poll answers. We can find and delete a question or a text answer if you tell us the session and what you wrote.

You can also contact:

9. Further information

Record of processing: [TO CONFIRM: reference in the Data Protection Officer’s register]

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