Kiri

EUROPEAN COMMISSION DIRECTORATE-GENERAL FOR EMPLOYMENT, SOCIAL AFFAIRS AND INCLUSION

Directorate B5 – Professional Qualifications and Skills for Competitiveness

Brussels

EMPL.B.5/MS/ (2026)1687120

TO WHOM IT MAY CONCERN

Subject: Accreditation for the Study supporting the identification of professions for

the extension of automatic recognition through common training

frameworks under Directive 2005/36/EC

Dear Sir, / Dear Madam,

I would like to inform you that Spark Legal and Policy Consulting, with the support of 3s

Unternehmensberatung GmbH, is currently conducting the study supporting the

identification of professions for the extension of automatic recognition through Common

Training Frameworks (CTFs) on behalf of the European Commission’s Directorate-General

for Employment, Social Affairs and Inclusion.

The objective of this study is to support the European Commission in identifying the

professions that may be suitable for the development of CTFs under Directive 2005/36/EC,

by examining the following aspects:

• the regulatory landscape of professions across Member States, including the extent to

which comparable professional activities, qualifications, and training requirements

exist;

• the presence of labour‑market needs and skills shortages across Europe, in order to

identify professions where enhanced mobility could provide added value;

• the feasibility of developing a CTF for the selected professions, based on the presence

of shared core knowledge, skills, and competences, and the added value such

frameworks could provide for the internal market and cross-border mobility;

• the specific components that a potential CTF could comprise, taking into account

existing commonalities and the practical considerations necessary for its

implementation.

The results of the study will allow the European Commission to adopt informed future

decisions.

The study is part of an EU-level Skills Portability Initiative (SPI) aiming to propose

legislative and technical solutions to strengthen the transferability of qualifications and

skills. The initiative includes three separate, yet highly interlinked Actions:

• Action 1: Recognition of qualifications and validation of skills for both regulated and

unregulated professions (for EU and third country nationals)

• Action 2 (the current study): Recognition of qualifications for access to regulated

professions, including the setting of common training frameworks to facilitate recognition

of professional qualifications.

• Action 3: EU rules for the recognition of qualifications and validation of skills of third

country nationals.

During the study, Spark will conduct consultation activities to which we kindly invite you

to contribute. Your insights will be essential to shaping the study’s findings and identifying

potential common training frameworks to streamline recognition procedures for the

professions identified. Direct feedback from relevant stakeholders is an essential element

for the quality and usefulness of this study. To ensure the success of this exercise, the

European Commission will be grateful for your assistance to the team of external evaluators

and for providing them with the information necessary for their assignment.

Please note that all information provided will be treated with the utmost confidentiality and

used solely for the purposes of this study. We greatly appreciate your time and consideration

in supporting this important initiative.

For any enquiries on this study and the purpose of the consultations, please contact the study

team and notably Ms Anna Rossa at Spark Legal and Policy Consulting

([email protected])

Thank you in advance for your active cooperation.

Yours sincerely,

Steven ENGELS

Head of unit

(e-signed)

Electronically signed on 12/02/2026 09:10 (UTC+01) in accordance with Article 11 of Commission Decision (EU) 2021/2121

EUROPEAN COMMISSION DIRECTORATE-GENERAL FOR EMPLOYMENT, SOCIAL AFFAIRS AND INCLUSION

Directorate B5 – Professional Qualifications and Skills for Competitiveness

Brussels

EMPL.B.5/MS/ (2026)1687120

TO WHOM IT MAY CONCERN

Subject: Accreditation for the Study supporting the identification of professions for

the extension of automatic recognition through common training

frameworks under Directive 2005/36/EC

Dear Sir, / Dear Madam,

I would like to inform you that Spark Legal and Policy Consulting, with the support of 3s

Unternehmensberatung GmbH, is currently conducting the study supporting the

identification of professions for the extension of automatic recognition through Common

Training Frameworks (CTFs) on behalf of the European Commission’s Directorate-General

for Employment, Social Affairs and Inclusion.

The objective of this study is to support the European Commission in identifying the

professions that may be suitable for the development of CTFs under Directive 2005/36/EC,

by examining the following aspects:

• the regulatory landscape of professions across Member States, including the extent to

which comparable professional activities, qualifications, and training requirements

exist;

• the presence of labour‑market needs and skills shortages across Europe, in order to

identify professions where enhanced mobility could provide added value;

• the feasibility of developing a CTF for the selected professions, based on the presence

of shared core knowledge, skills, and competences, and the added value such

frameworks could provide for the internal market and cross-border mobility;

• the specific components that a potential CTF could comprise, taking into account

existing commonalities and the practical considerations necessary for its

implementation.

The results of the study will allow the European Commission to adopt informed future

decisions.

The study is part of an EU-level Skills Portability Initiative (SPI) aiming to propose

legislative and technical solutions to strengthen the transferability of qualifications and

skills. The initiative includes three separate, yet highly interlinked Actions:

• Action 1: Recognition of qualifications and validation of skills for both regulated and

unregulated professions (for EU and third country nationals)

• Action 2 (the current study): Recognition of qualifications for access to regulated

professions, including the setting of common training frameworks to facilitate recognition

of professional qualifications.

• Action 3: EU rules for the recognition of qualifications and validation of skills of third

country nationals.

During the study, Spark will conduct consultation activities to which we kindly invite you

to contribute. Your insights will be essential to shaping the study’s findings and identifying

potential common training frameworks to streamline recognition procedures for the

professions identified. Direct feedback from relevant stakeholders is an essential element

for the quality and usefulness of this study. To ensure the success of this exercise, the

European Commission will be grateful for your assistance to the team of external evaluators

and for providing them with the information necessary for their assignment.

Please note that all information provided will be treated with the utmost confidentiality and

used solely for the purposes of this study. We greatly appreciate your time and consideration

in supporting this important initiative.

For any enquiries on this study and the purpose of the consultations, please contact the study

team and notably Ms Anna Rossa at Spark Legal and Policy Consulting

([email protected])

Thank you in advance for your active cooperation.

Yours sincerely,

Steven ENGELS

Head of unit

(e-signed)

Electronically signed on 12/02/2026 09:10 (UTC+01) in accordance with Article 11 of Commission Decision (EU) 2021/2121

February 2026

Privacy statement for targeted consultation activities

EUROPEAN COMMISSION

PROTECTION OF YOUR PERSONAL DATA

Processing operation: Targeted consultation activities (including surveys, interviews and focus groups) in the

framework of the study supporting the identification of professions for the extension of automatic recognition

through common training frameworks under Directive 2005/36/EC.

Controller: European Commission, Directorate-General Employment, Social Affairs and Inclusion, Unit

Financial Implementation and Procurement Centre.

Processor: Spark Legal and Policy Consulting Record reference: DPR-EC-01011

Table of Contents

1. Introduction

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

3. On what legal ground(s) do we process your personal data?

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

5. How long do we keep your personal data?

6. How do we protect and safeguard your personal data?

7. Who has access to your personal data and to whom is it disclosed?

8. What are your rights and how can you exercise them?

9. Contact information

10. Where to find more detailed information?

April 2026

1. Introduction

The European Commission (hereafter ‘the Commission’) is committed to protect your personal data and to

respect 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.

This privacy statement concerns the processing operation targeted surveys, undertaken by the Commission,

Directorate-General Employment, Social Affairs and Inclusion, as presented below.

The processor, Spark Legal and Policy Consulting, is based in the European Union.

2. 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 to obtain your views on a specific initiative, policy or

intervention.

You are being contacted by Spark Legal and Policy Consulting since the processor has concluded that your

views are relevant and necessary to inform the Study supporting the identification of professions for the

extension of automatic recognition through common training frameworks under Directive 2005/36/EC,

concerned by the targeted consultation.

April 2026

Spark Legal and Policy Consulting collected your contact details from the internet where they have been

manifestly made public by you or the organisation you work for. You have been identified by Spark Legal and

Policy Consulting as a stakeholder whose views are relevant and necessary to achieve the specific purpose of

the targeted consultation activity in the public interest as described below. Your participation in the targeted

consultation activity is completely voluntary.

More specifically, the processing operation concerns the following processing activities and purposes:

− to obtain the views of the respondents of a targeted consultation activity for the design, evaluation

and revision of policies, initiatives and interventions. To design, evaluate and revise initiatives it is

indispensable for the Commission to receive input and views from those who are considered to be

concerned by the policy, initiative or intervention.

For reasons of transparency and openness your views will, in principle, be published on a Europa website. The

Commission only publishes your identity if you consent to the publication.

To avoid misuse, anonymous contributions may not be accepted, regardless whether you consent to the

publication of your identity together with your contribution.

− The consultation activity uses the Commission's online questionnaire tool EUSurvey that requires you

to login via your ‘EU Login’ or ‘social media account’. ‘EU Login’ requires certain personal data such

as the name, surname and e-mail address of the registrant. For further information, please refer to

the privacy statements of ‘EU Login’ and ‘EU Survey’ as well as the processing operations ‘Identity &

Access Management Service (IAMS)' (reference number in the public DPO register: DPR-EC-03187)

and ‘EUSurvey’ (reference number: DPR-EC-01488). Should you choose to log in through your social

media account, please refer to the pertinent social media platform’s privacy statement.

− The subject matter of the consultation activity require you to provide personal data in your response

that may identify or make you identifiable. These personal data will only be published subject to your

explicit consent.

− It is your responsibility if you opt for confidentiality of your personal data to avoid any reference in

your submission or contribution itself that would reveal your identity.

− Your contribution to the targeted consultation is stored in the Commission’s document management

system (for further information on the Commission’s document management system please refer to

the processing operation ‘Management and (short- and medium-term) preservation of Commission

documents`, reference number: DPR-EC-00536).

April 2026

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 Auditor.

Your personal data will not be used for an automated decision-making including profiling.

3. 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) 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.

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

In order to carry out this processing operation, Spark Legal and Policy Consulting collects the following

categories of personal data:

• name and surname,

• e-mail address of the respondent,

• the name of a self-employer individual (natural persons) on whose behalf the respondent is contributing,

• personal data included in the response or contribution to the targeted consultation activity, including

(personal) opinions.

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

April 2026

considered to provide his/her explicit consent to the processing, in accordance with Article 10(2)(a) of

Regulation 2018/1725.

5. 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(2019)900. 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 Historical Archives, please see record of processing 'Management and long-term

preservation of the European Commission's Archives’, registered under reference number DPR-EC-00837).

Upon expiry of its contract with the Commission on July 2026, Spark Legal and Policy Consulting shall, at the

choice of the data controller, return to the controller, without any undue delay in a commonly agreed format,

all personal data processed on behalf of the controller and the copies thereof or shall effectively delete all

personal data unless Union or national law requires a longer storage of personal data.

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 Commission or of its processors (Spark Legal and Policy Consulting). All processing

April 2026

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.

The Commission’s processors (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.

7. 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 carrying out this processing

operation 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.

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.

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 and to rectify them in case your personal data are inaccurate

or incomplete. Under certain conditions, you have the right to erase your personal data, to restrict the

April 2026

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 you 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 case you will be informed

of the extension of the time limit, together with the reasons for the delay.

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, please feel free to contact the Data Controller.

European Commission, Directorate-General Employment, Social Affairs and Inclusion, Unit Financial

Implementation and Procurement Centre at [email protected]

For any such communication please indicate VC - No 30014181 in the subject matter.

- The Data Protection Officer (DPO) of the Commission

You may contact the Data Protection Officer ([email protected]) with regard to

April 2026

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.

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 public register with the following Record

reference: DPR-EC-01011.

February 2026

Privacy statement for targeted consultation activities

EUROPEAN COMMISSION

PROTECTION OF YOUR PERSONAL DATA

Processing operation: Targeted consultation activities (including surveys, interviews and focus groups) in the

framework of the study supporting the identification of professions for the extension of automatic recognition

through common training frameworks under Directive 2005/36/EC.

Controller: European Commission, Directorate-General Employment, Social Affairs and Inclusion, Unit

Financial Implementation and Procurement Centre.

Processor: Spark Legal and Policy Consulting Record reference: DPR-EC-01011

Table of Contents

1. Introduction

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

3. On what legal ground(s) do we process your personal data?

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

5. How long do we keep your personal data?

6. How do we protect and safeguard your personal data?

7. Who has access to your personal data and to whom is it disclosed?

8. What are your rights and how can you exercise them?

9. Contact information

10. Where to find more detailed information?

April 2026

1. Introduction

The European Commission (hereafter ‘the Commission’) is committed to protect your personal data and to

respect 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.

This privacy statement concerns the processing operation targeted surveys, undertaken by the Commission,

Directorate-General Employment, Social Affairs and Inclusion, as presented below.

The processor, Spark Legal and Policy Consulting, is based in the European Union.

2. 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 to obtain your views on a specific initiative, policy or

intervention.

You are being contacted by Spark Legal and Policy Consulting since the processor has concluded that your

views are relevant and necessary to inform the Study supporting the identification of professions for the

extension of automatic recognition through common training frameworks under Directive 2005/36/EC,

concerned by the targeted consultation.

April 2026

Spark Legal and Policy Consulting collected your contact details from the internet where they have been

manifestly made public by you or the organisation you work for. You have been identified by Spark Legal and

Policy Consulting as a stakeholder whose views are relevant and necessary to achieve the specific purpose of

the targeted consultation activity in the public interest as described below. Your participation in the targeted

consultation activity is completely voluntary.

More specifically, the processing operation concerns the following processing activities and purposes:

− to obtain the views of the respondents of a targeted consultation activity for the design, evaluation

and revision of policies, initiatives and interventions. To design, evaluate and revise initiatives it is

indispensable for the Commission to receive input and views from those who are considered to be

concerned by the policy, initiative or intervention.

For reasons of transparency and openness your views will, in principle, be published on a Europa website. The

Commission only publishes your identity if you consent to the publication.

To avoid misuse, anonymous contributions may not be accepted, regardless whether you consent to the

publication of your identity together with your contribution.

− The consultation activity uses the Commission's online questionnaire tool EUSurvey that requires you

to login via your ‘EU Login’ or ‘social media account’. ‘EU Login’ requires certain personal data such

as the name, surname and e-mail address of the registrant. For further information, please refer to

the privacy statements of ‘EU Login’ and ‘EU Survey’ as well as the processing operations ‘Identity &

Access Management Service (IAMS)' (reference number in the public DPO register: DPR-EC-03187)

and ‘EUSurvey’ (reference number: DPR-EC-01488). Should you choose to log in through your social

media account, please refer to the pertinent social media platform’s privacy statement.

− The subject matter of the consultation activity require you to provide personal data in your response

that may identify or make you identifiable. These personal data will only be published subject to your

explicit consent.

− It is your responsibility if you opt for confidentiality of your personal data to avoid any reference in

your submission or contribution itself that would reveal your identity.

− Your contribution to the targeted consultation is stored in the Commission’s document management

system (for further information on the Commission’s document management system please refer to

the processing operation ‘Management and (short- and medium-term) preservation of Commission

documents`, reference number: DPR-EC-00536).

April 2026

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 Auditor.

Your personal data will not be used for an automated decision-making including profiling.

3. 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) 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.

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

In order to carry out this processing operation, Spark Legal and Policy Consulting collects the following

categories of personal data:

• name and surname,

• e-mail address of the respondent,

• the name of a self-employer individual (natural persons) on whose behalf the respondent is contributing,

• personal data included in the response or contribution to the targeted consultation activity, including

(personal) opinions.

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

April 2026

considered to provide his/her explicit consent to the processing, in accordance with Article 10(2)(a) of

Regulation 2018/1725.

5. 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(2019)900. 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 Historical Archives, please see record of processing 'Management and long-term

preservation of the European Commission's Archives’, registered under reference number DPR-EC-00837).

Upon expiry of its contract with the Commission on July 2026, Spark Legal and Policy Consulting shall, at the

choice of the data controller, return to the controller, without any undue delay in a commonly agreed format,

all personal data processed on behalf of the controller and the copies thereof or shall effectively delete all

personal data unless Union or national law requires a longer storage of personal data.

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 Commission or of its processors (Spark Legal and Policy Consulting). All processing

April 2026

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.

The Commission’s processors (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.

7. 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 carrying out this processing

operation 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.

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.

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 and to rectify them in case your personal data are inaccurate

or incomplete. Under certain conditions, you have the right to erase your personal data, to restrict the

April 2026

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 you 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 case you will be informed

of the extension of the time limit, together with the reasons for the delay.

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, please feel free to contact the Data Controller.

European Commission, Directorate-General Employment, Social Affairs and Inclusion, Unit Financial

Implementation and Procurement Centre at [email protected]

For any such communication please indicate VC - No 30014181 in the subject matter.

- The Data Protection Officer (DPO) of the Commission

You may contact the Data Protection Officer ([email protected]) with regard to

April 2026

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.

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 public register with the following Record

reference: DPR-EC-01011.