EUROPEAN COMMISSION
PROTECTION OF YOUR PERSONAL DATA
Processing operation: Targeted consultation activities (including surveys, interviews and focus
groups) to support the European Commission’s initiative to prevent gold-plating practices.
Controller: European Commission, DG GROW.B1 Planning & Simplification
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?
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 EU Questionnaires to Member States
and business stakeholders about gold-plating in EU Member States, undertaken by the
Commission DG GROW.B1 in charge of Planning & Simplification as presented below.
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 aiming to minimise gold-
plating of Single Market acquis.
The Communication A Simpler, Clearer and Better Enforced EU Rulebook adopted in April 2026
includes an extensive point on tackling gold-plating. It indicates that “the Commission will work
on a toolkit of best practices and criteria to help Member States identify and avoid gold-plating
in the national transposition and implementation of EU legislation”.
As per the above-mentioned Communication and the intention to support “Member States in
their commitment to avoid gold-plating through a toolkit with best practices and transposition
guidance”, Member States and business stakeholders are invited to provide the input that will
be used to deliver the Toolkit. The survey invites the Member States and business stakeholders
to share their views on gold-plating in the areas of Single Market acquis.
You are being contacted by DG GROW.B1 since it has been concluded that your views are
relevant and necessary to inform the gold-plating toolkit concerned by the targeted
consultation.
DG GROW.B1 collected and processes your contact details since you subscribed to, and thus
gave your consent to, be part of a mailing list to be informed of / contacted in case of future
consultations by the Commission in case of data needs from the Member States or business
stakeholders (e.g. EEN networks, Industry Forum and newsletter mailing lists of DG GROW).
For Member States, the survey is being disseminated via the Secretariat of the Council of the EU
(Better Regulation Working Party).
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.
Your views and contributions will not be published on a website directly as received; they will be
published in the form of a summary report, or included in a wider policy document (Gold-plating
toolkit). Your identity will not be published but it is your responsibility if you opt for
confidentiality of your personal data to avoid any reference in your submission or contribution
that would reveal your identity.
To avoid misuse, anonymous contributions to the Commission may not be accepted, regardless
of whether you consent to the publication of your identity together with your contribution.
The subject matter of the consultation activity requires you to provide personal data in your
response that may identify or make you identifiable.
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.
Your contribution to the targeted consultations 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).
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 Auditors.
Your personal data will not be 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:
(a) processing is necessary for the performance of a task carried out in the public interest;
(c) it is based on your consent, for one or more specified purposes:
− If the subject matter of a targeted consultation requires respondents to provide
personal data in their response that make the data subject identifiable, their
publication;
− to be contacted by the Commission for the present consultation (in case you had
previously consented to be contacted by the Commission for such type of consultation).
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, read
in conjunction with Recital 22 of Regulation (EU) 2018/172 Article 298 of the Treaty on the
Functioning of the European Union, 5), as well as the Protocol 2 on the application of the
principles of subsidiarity and proportionality.
The Communication COM(2026) 380 final A Simpler, Clearer and Better Enforced EU Rulebook
adopted in April 2026 includes an extensive point on tackling gold-plating. It indicates that “the
Commission will work on a toolkit of best practices and criteria to help Member States identify
and avoid gold-plating in the national transposition and implementation of EU legislation”.
4. Which personal data do we collect and further process?
In order to carry out this processing operation DG GROW.B1 collects the following categories of
personal data:
• name and surname,
• profession,
• country of residence,
• e-mail address of the respondent,
• the name, size, type and transparency number of the organisation on whose behalf the
respondent is contributing
• the name of an administrative authority on whose behalf the respondent is contributing,
• the name of a self-employed 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 (if the targeted consultation at hand requires so).
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 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).
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 contractors (processors). 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
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 the 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 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, DG GROW.B1 at
[email protected]
- The Data Protection Officer (DPO) of the Commission
You may contact the Data Protection Officer (
[email protected])) with
regard to 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.
.
Resolutsiooni liik: Riigikantselei resolutsioon
Viide: Justiits- ja Digiministeerium / / ; Riigikantselei / / 4-2/26-01640
Resolutsiooni teema: "Gold-plating" avalik konsultatsioon
Adressaat: Justiits- ja Digiministeerium
Ülesanne: Tulenevalt 19.08.2026 EL koordinatsioonikogu otsusest palun esitada seisukohad
Euroopa Komisjoni poolt avaldatud avaliku konsultatsiooni kohta:
Gold-plating – EU survey to Member States – Message from the Commission
EISi toimiku nr: 26-0357
Viide avalikule konsultatsioonile: https://ec.europa.eu/eusurvey/runner/GoldplatingMemberStates
Tähtaeg: 04.09.2026
Adressaat: Haridus- ja Teadusministeerium, Kaitseministeerium, Kliimaministeerium,
Kultuuriministeerium, Majandus- ja Kommunikatsiooniministeerium, Rahandusministeerium,
Regionaal- ja Põllumajandusministeerium, Siseministeerium, Sotsiaalministeerium,
Välisministeerium
Ülesanne: Palun esitada oma sisend Justiits- ja Digiministeeriumile seisukohtade kujundamiseks
antud avaliku konsultatsiooni kohta (eelnõude infosüsteemi (EIS) kaudu).
Tähtaeg:
Lisainfo: Eesti seisukohad avaliku konsultatsiooni kohta on kavas heaks kiita kirjalikus menetluses
09.09.2026 EL koordinatsioonikogu istungil. Esialgsed materjalid EL koordinatsioonikoguks palume
esitada hiljemalt 04.09.2026.
Kinnitaja: Merli Vahar, Euroopa Liidu asjade direktori asetäitja
Kinnitamise kuupäev: 26.08.2026
Resolutsiooni koostaja: Sandra Metste
[email protected],