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
- Your answers to polls, quizzes and surveys, and any text you type.
- Questions you submit and the questions you upvote.
- A display name, only if you choose to add one to a question.
- A random identifier stored in your browser. It is valid for one session only. It prevents double counting and lets you keep your answers when the page reloads. It is not linked to your name, your email address or your Commission account.
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
- Your email address, used to send you sign-in links.
- The sessions you create and what you do in them.
- For administrators, a record of each administrative action and when it was made.
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:
- In a very small group, or because of what you write, others may be able to guess who gave an answer.
- Do not include personal information about yourself or other people in free text or questions.
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
- A session and everything in it is deleted one year after the session closes.
- An open session that is no longer used closes automatically after 30 days without activity.
- An organiser can delete a session earlier at any time.
- Deleted data leaves backups within 30 days.
- Organiser email addresses are kept for as long as the person is an authorised organiser.
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:
- the organiser and co-organisers of a session, for that session only;
- administrators of the tool, who can see the list of sessions but not their content;
- the technical team that maintains the pilot, where needed to fix a problem.
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:
- the Commission’s Data Protection Officer: data-protection-officer@ec.europa.eu
- the European Data Protection Supervisor, if you wish to lodge a complaint: edps@edps.europa.eu
9. Further information
Record of processing: [TO CONFIRM: reference in the Data Protection Officer’s register]