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DPO-3777.4 EU Health Policy Platform

Directorate-General: DG Health and Food Safety

Controller: ROUX Philippe

Publication: 2018-03-22

Processing

1. Name of the processing

EU Health Policy Platform

2. Description

The mandate of the EU Health Policy Forum ended in December 2013. In the meantime, the Commission adopted a new approach for systematic large scale public consultations (including health stakeholders) for all Commission policy or regulatory initiatives. DG Health and Food Safety (SANTE) therefore reviewed the Forum concept with a view to better reflect the priorities of the Commission in its dialogue with the stakeholders.

The EU Health Policy Forum evolves from a consultative group to a multilateral communication channel between the Commission and its health stakeholders, by creating a collaborative interactive platform, the EU Health Policy Platform, hereby HPP. It is no longer focused on consultation as the European Commission has put in place an official procedure making large consultations with stakeholders compulsory. In turn, the HPP focuses on creating a space for permanent dialogue on health issues amongst all possible health stakeholders and with the European Commission. With this new objective and the fact that there is no fixed membership any longer, the Platform ceases to exist as an expert group and loses its consultative feature, thus being deleted from the Registry of Expert Groups of the European Commission .

The new format of the HPP  is conceived to increase the sharing of ideas and good practices between public health stakeholders in the EU themselves and between them and the Commission.

The HPP is a web platform that operates through the following three axes: (1) Web Platform to enable online discussion and collaboration including preparation of Joint Statements on public health issues by NGOs; (2) face-to-face meetings, to present the Joint Statements and host targeted thematic discussions; (3) EU Health Award for NGOs.

Within the HPP there are four types of networks :

(1) The Agora Network, as an open discussion area accessible to all stakeholders who registered in the Web Platform (targeted users related to the field of Public Health);

(2) Four temporary Thematic Networks accessible to all registered users to facilitate their drafting of Joint Statements on chosen health issues ;

(3) An Exchange network, “Fems: Doctors’ working conditions and remuneration across Europe”, which aim is to discuss about ways to improve doctors' working conditions and remuneration across Europe;

(4) EU Expert and Stakeholder Groups, networks only accessible to members of existing DG SANTE’s EU Expert and Stakeholder Groups.


When clicking on the Log-In tab, present in the EU Health Policy Platform webpage, stakeholders will be directed to an interactive platform where, after registration (via European Commission Authentication Service-ECAS/ EU-login) and request of access, they become part of a general network named Agora Network and then, upon request, of other specific Thematic and Exchange as well as Expert and Stakeholder networks according to their needs and field of expertise. Each network has a newsfeed where stakeholders can post items (comments, links or documents) with different degrees of restriction (to all networks - through Agora, only to my network). They are able to comment on posts and discuss new ideas. Each network member is able to exchange and store documents, promote and participate in events, create opinion polls, start a discussion and request access to another network. More networks are regularly created according to the needs of DG Health and Food Safety and stakeholders.

One year after its launch on 21 April 2016, the HPP counts more than 1000 users, over 40 expert and stakeholder groups and four new Thematic Networks that are working on the Joint Statements.

All exchange of information done in the HPP’s Agora Network is validated a posteriori by a moderator from the Commission services, following the Terms and Conditions as well as the Working Methods of the HPP which includes references to good practices to be followed by registered users. The Expert and Stakeholder Groups Networks are managed and moderated by designated stakeholder representatives or, where applicable, the policy officer in charge of the specific file.

No personal data is processed which falls under Article 27 "Prior checking" of Regulation (EC) No 45/2001.

3. Sub-Contractors

N/A

4. Automated / Manual operations

Visitors of the website will be prompted to register to the HPP. If they haven't done so, they are asked to create an ECAS/EU-login account. Once they have this account, they can enter first in the Platform and then request access to the Agora network, which is the general part common to all registered users. Afterwards, they can then also request to become members of specific networks. The request is sent and validated by the Commission policy officer, or by other moderator of the network, through the SAAS2 authorisation system.

5. Storage

The collected personal data and all related information are stored on DG DIGIT servers.

6. Comments

N/A

Purpose & legal basis

7. Purposes

The purpose of the processing through registration is to allow the stakeholders to better communicate amongst themselves and with the Commission services, to disseminate their views within the specific network they belong to and to be informed about events and information relevant to Health in all policies through the HPP.

Regarding the EU Health Award: upon reception of the applications by DG SANTE, personal data is collected and further processed for the purpose of the management and administration of the  winners selection by the Commission services.

8. Legal basis / Lawfulness

Article 11 of the consolidated European Treaty on the European Union states: “The institutions shall, by appropriate means, give citizens and representative associations the opportunity to make known and publicly exchange their views in all areas of Union action. The institutions shall maintain an open, transparent and regular dialogue with representative associations and civil society”.

REGULATION (EU) No 282/2014 of the European Parliament and of the Council of 11 March 2014 on the establishment of a third Programme for the Union's action in the field of health (2014-2020) and repealing Decision No 1350/2007/EC, L 86/1, 21.3.2014 (Third EU Health Programme 2014-2020) (http://ec.europa.eu/health/programme/policy/index_en.htm) and its corresponding work plans.

The yearly commission implementing decision implementing the work programme (including annexes) makes reference to the implementation of the HPP, as well as to the implementation of the EU Health Award, which is part of the HPP.

Council Regulation (EC, Euratom) N° 966/2012 of 25 October 2012 on the financial rules applicable to the general budget of the Union and repealing Council Regulation (EC, Euratom) No 1605/2002 "the Financial Regulation", in particular Articles 106 (1), 107 (1), 138 (2), Article 132 (1), Article 132 (2).

Commission Delegated Regulation (EU) No 1268/2012 of 29 October 2012 on the rules of application of Regulation (EU, Euratom) No 966/2012 of the European Parliament and of the Council on the financial rules applicable to the general budget of the Union, "the Implementing Rules", in particular Article 202 and Article 203.

The l
awfulness of processing is based specifically on Article 5(a): the tasks are carried out in the public interest; article 5(b): processing is necessary for compliance with a legal obligation to which the controller is subject; and article 5(d): the data subject has unambiguously given consent, all foreseen in Regulation 45/2001 of the European Parliament and of the Council of 18 December 2000 on the protection of individuals with regard to the processing of personal data by the Community institutions and bodies and on the free movement of such data.


  

Data subjects / fields

9. Data subjects

The data subjects concerned are members of already established EU Expert and Stakeholder Groups of DG Health and Food Safety, European Commission staff and health stakeholders involved in health policy who are registered in the Platform. Policy officers of the European Commission act as moderators of the EU Experts and Stakeholder Groups.

10. Data fields

EU Health Policy Platform

The data fields are the personal data required in order to sign up to ECAS: e-mail address, first name, last name, username. The e-mail address will only be visible to the system administrator.

Furthermore, each stakeholder, who is a member of a network, will be able to create a profile by entering, at his choice, the following personal data categories: name, surname, picture, and location, email addresses (personal and professional), phone number, skype address, memberships in the networks, and organisation he/she belongs to, as well as comments / opinions. These data are published on his/her profile and will be visible to all stakeholders registered in the HPP. No data fields concern racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, health or sex life.

The discussions in the group will never be related to a specific individual's personal health data. In the HPP there are recommendations specifying that the discussions should never reveal health-related data of individuals. The Networks (Thematic, Exchange, Expert and Stakeholder Groups Networks) will discuss, among other things, studies, projects, and policies related to specific topics.

Regarding specifically the EU Health Award, p ersonal data collected and further processed concerns the non-governmental bodies (civil society organisations) participating in the selection procedure for the EU Health Award for NGOs. Information can relate to all, or some, of the following data:

  • Name of the organisation;
  • Name of the contact person;
  • Description of the organisation aims and mission;
  • Function of the contact person;
  • Contact details (e-mail address, business phone number, mobile phone number, fax number, postal address, company and department, country of residence, internet address);
  • Information for the evaluation of selection criteria or eligibility criteria: the information is focused on the best practice submitted, summary, added value at EU level, and detailed description of how the best practice is relevant, effective, cost-effective, has transferability potential, is sustainable, allows intersectional collaboration and is presented with an innovative and creative approach;
  • Declaration of honour stating that the applicants are not in one of the exclusion situations referred to in Articles 106 and 107 of the Financial Regulation.

Upon reception of applications by DG SANTE, personal data is processed, by the Commission services, for the purpose of the management and administration of the winners' selection.

Rights of D.S.

11. Information

ECAS (Notification DPO-839.2) is used to authenticate users of Health Policy Platform network and SAAS2 (Notification DPO-2065.3) to authorize them to become members of the specific networks. In addition, a specific privacy statement (SPS) for the EU Health Policy Platform (see annex) is published on the platform's website, as well as in the EU Health Award submission module (data subjects are required to tick a box indicating they have read and accepted the EU Health Award privacy policy).

12. Procedure to grant rights

Regarding personal data processed in EU Login / ECAS, data subjects are entitled to access, verify and correct it themselves, at any time. In order to delete their profile, however, they need to send an email to the EU Login / ECAS system contact point (a functional mailbox indicated in the EU Health Policy Platform SPS). Regarding SAAS2, users have to contact the administrator, by sending an email to the functional mailbox indicated in the SPS, in order to exercise their rights. As for the deletion of the users' personal data in SAAS2, this occurs two months after the deletion in EU Login / ECAS. If the user wants to erase their personal data in SAAS2 before the expiration of the two-month period, they are required to send an email to the functional mailbox indicated in the EU Health Policy Platform SPS.

Personal data entered in a network member's profile in the EU Health Policy Platform can be accessed, verified, corrected and deleted by the users themselves at any given time.

As regards the EU Health Award, in case the data subject wishes to verify which personal data is stored, have it modified, corrected, deleted, or object to its processing or if they have questions regarding the personal information processed in the context of the meeting, or concerning their rights, they can contact the support team by explicitly specifying their request at the addresses provided in the Specific Privacy Statement.

13. Retention

Personal data of the users will be kept for as long as their account is active. After two months after the deletion from ECAS of the user profile, personal data will be also deleted by SAAS2. For the data in SAAS2, once a person is removed from any access to any DG SANTE system, the data will not be kept longer than one month after the initial date of deletion.

When it concerns the EU Health Award, the data subjects' personal data will be used for the abovementioned purposes and kept:

  • Until the end of the EU Health Award procedure (1 year from announcement), and in the archives for a period of 5 years following the ceremony; which leads to a total of 6 years;
  • Until the end of a possible audit, if one was started during the above-mentioned 6 years.

14. Time limit

The time limit to reply to a request from the data subjects is usually one working day and in any case no longer than 15 days.

15. Historical purposes

N/A

Recipients

16. Recipients

Only users registered in the HPP will be able to read the comments and the personal data (first name and family name of the contributor, picture and organisation) related to the post, and only if the person chose to make the post visible to the whole Platform community by using the Agora News or only to the Network he/she belongs to.

Access to the data subjects' personal data submitted through their application for the EU Health Award is given to the following persons, without prejudice to a possible transmission to the bodies in charge of a monitoring or inspection task in accordance with European Union law:
  • Commission staff, as well as external experts and contractors who work on behalf of the Commission for the purposes of management of the selection procedure, and the bodies charged with a monitoring or inspection task in application of Union law (e.g. internal audits, Financial Irregularities Panel, European Anti-fraud Office - OLAF);
Access to the personal data of data subjects submitted through their application as contact points of an organisation is not provided to the members of the public via the EU Health Policy Platform or the EU Health Award without prior consent of the data subjects.

17. Transfer

If personal data are published on a publicly available website this means that they are accessible worldwide. Following the opinion of the EDPS of 13/02/2007, this does not constitute a transfer of personal data under Art. 9 of Regulation 45/2001. The participants have to be aware of such a publication and the opportunity has to be given to them to opt out on legitimate grounds. Nevertheless, no personal data is disseminated or made available outside the platform without prior request to and consent from the relevant data subjects.