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WHOISWHO augmented: PROTECTION OF YOUR PERSONAL DATA

PROTECTION OF YOUR PERSONAL DATA

Processing operation: EU Whoiswho - internal view

Data Controller: Publications Office of the European Union, unit A.5 "Portal and Web Services"

Record reference: DPR-EC-00447

1. 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.

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.

EU Whoiswho – official directory of EU staff - has a public version and an internal version for the use of EU staff. This privacy statement applies specifically to the internal directory. The information in relation to processing operation "EU Whoiswho – Internal Directory of the European Union" undertaken by unit A.5 "Portal and Web Services" of the Publications Office of the European Union, is presented below.

2. Why and how do we process your personal data?

Purpose of the processing operation: : Unit A.5 "Portal and Web Services" of the EU Publications Office collects and uses your personal information for publication in the internal directory of EU Whoiswho, accessible at https://op.beta.msop.spikeseed.cloud/web/who-is-who.

Staff of EU institutions, bodies, offices and agencies can access the EU Whoiswho internal directory when they authenticate via EU Login. The internal directory displays extended personal data — including job descriptions and portrait photos — of all staff in the European Commission’s services.

The processing operation consists of making contact and organisational information available to authorised EU staff to facilitate internal communication, collaboration and the operational functioning of EU institutions.

Your personal data is not 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:

  • processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Union institutions, bodies, offices and agencies;
  • processing is necessary for compliance with a legal obligation to which the controller is subject;
  • processing is necessary for the performance of a contract to which the data subject is party (staff employment relationship with EU institutions, bodies, offices and agencies).

Legal basis: mandate of the EU Publications Office, Decision 2009/496/EC, Euratom of the European Parliament, the Council, the Commission, the Court of Justice, the Court of Auditors, the European Economic and Social Committee and the Committee of the Regions of 26 June 2009 on the organisation and operation of the Publications Office of the European Union; and Article 15 TFEU (transparency obligation).

The internal directory is also regulated by the internal arrangement Ares(2026)4621554, signed in May 2026 between the EU Publications Office and DG HR. The internal arrangement governs the display of the internal directory of all services and staff and defines the responsibilities of the involved DGs as controller and processor.

Special categories of personal data: The internal directory may process data revealing trade union membership, in cases where European Commission staff are placed at the disposal of a trade union and displayed under it.

4. Which personal data do we collect and further process?

In order to carry out this processing operation, Unit A.5 "Portal and Web Services" of the EU Publications Office collects the following categories of personal data:

surname and first name, formal titles, professional e-mail address, office telephone number, function title, job description and portrait photo. For all data subjects, the generic work address (building), generic e-mail address and central telephone number of the organisation are also listed. The internal directory covers all staff of the European Commission’s services, including non-managerial positions.

The choice of the data processed is at the discretion of the participating EU institutions, bodies, offices and agencies. We receive your personal data from your unit/department in charge of human resources, via an automated or semi-automated data transfer (Sysper/COMREF for European Commission services and executive agencies).

A complete overview of data categories per institution is contained in the attachment "EU Whoiswho data types" (DPR-EC-00447).

5. How long do we keep your personal data?

Unit A.5 "Portal and Web Services" of the EU Publications Office keeps your personal data for as long as you are in active service within the EU institutions, bodies, offices or agencies. If you change your position within EU services, this will be reflected after a short delay in the internal directory of EU Whoiswho. If you leave EU services, your personal data will be removed from the internal view after a short delay.

The following retention rules apply: :

  • Active data: retained for as long as the data subject is in service
  • Data backups: retained for a maximum of 2 years.

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 EU Publications Office. The IT systems of the EU Publications Office are managed by DIGIT. 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 European Commission.

Access to the internal directory is possible for authenticated users of EU institutions, bodies, offices and agencies via EU Login. Technical and organisational measures are in place to ensure that only authorised users can access the extended data displayed in the internal directory. These measures include access controls, encryption in transit and regular security reviews.

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. Organisational measures include restricting access to 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 the personal data processed in the internal directory is provided to

  • Authorised staff of the EU Publications Office responsible for carrying out this processing operation, according to the "need to know" principle;
  • Authorised staff of DG HR (service responsible for COMREF), for data originating from COMREF/Sysper;
  • Authorised staff of EU institutions, bodies, offices and agencies, who can consult the internal directory via EU Login authentication;
  • The contractor responsible for hosting and maintaining the EU Whoiswho platformwho processes data on behalf of the EU Publications Office under appropriate data processing agreements.

All such staff abide by statutory and, where required, additional confidentiality agreements. The extended data displayed in the internal directory (job descriptions, portrait photos, data on non-managerial staff) is not made available to the general public, to the EU Open Data Portal, or to any external third party.

The internal directory data is not transferred to countries outside the EU or EEA, nor to international organisations.

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;
  • the right to rectify your personal data;
  • the right to erase your personal data;
  • the right to restrict the processing of your personal data;
  • the right to object to the processing; and
  • the right to data portability, where applicable.

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 Section 9 below.

Please note that for data originating from your institution's human resources system (e.g. Sysper/COMREF for Commission staff), requests for rectification should in the first instance be directed to your HR department, as the EU Publications Office relies on the data as provided by the source institution.

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 Section 10 below) in your request.

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, you can contact the Data Controller, Unit A.5 " Portal and Web Services" of the EU Publications Office at OP-DATA-PROTECTION-COORDINATOR@publications.europa.eu..

  • The Data Protection Officer (DPO) of the Commission

You may contact the Data Protection Officer (EC-DPO-INTERNAL@ec.europa.eu) with regard to issues related to the processing of your personal data under Regulation (EU) 2018/1725.

The Data Protection Coordinator of the EU Publications Office can be contacted at: OP-DATA-PROTECTION-COORDINATOR@publications.europa.eu.

  • The European Data Protection Supervisor (EDPS)

You have the right to have recourse to the European Data Protection Supervisor (edps@edps.europa.eu) 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 register with the following Record reference: DPR-EC-00447. The full record of processing (DPR-EC-00447.7) is available on the Commission's internal DPO register at: https://intragate.ec.europa.eu/dpms/record/DPR-EC-00447.7.

The internal arrangement governing the internal view of EU Whoiswho (Ares(2026)4621554), signed between the EU Publications Office and DG HR, is attached to the record of processing.