Data protection notice for the Social Media Use by the WEB-T

The European Commission is committed to protecting your personal data and to 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 (re-pealing 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 and the Data Protection Officer.

This privacy statement concerns the processing operation “WEB-T Social Media presence”, undertaken by the European Multilingual Web (EMW) consortium (WEB-T Consortium), on behalf of the Directorate General for Communications Networks, Content and Technology (CONNECT), Directorate G Data, Unit G.3 Accessibility, Multilingualism & Safer Internet, as presented below.

The WEB-T uses social media channels (namely Instagram, Facebook, LinkedIn and YouTube) to regularly inform the public about its activities, raise awareness about WEB-T development and use as well as to engage directly with potential and existing users by replying to their comments and questions. Users sign up to social media platforms on a voluntary basis, subject to the policies of social media platforms.

Depending on the circumstances, and depending on the social media platforms used, the WEB-T consortium has access to the following categories of data:

• Personal data derived from the users’ profile may include: name and surname, username, geographical area, age, gender and other personal characteristics, such as marital status, nationality, occupation or academic record.
• Personal data about users of social media platforms that is available through their networks and connections: engagement, reach and sentiment, comments, shares of users on a specific topic, networks, and connections.
• Personal data available via audio-visual content that might be published on social media platforms: information in or about the content provided by a user (e.g. metadata), such as the location of a photo or the date of when a file was created, voice recordings, video recordings, or an image of an individual.

 However, for statistical, analytical, and monitoring purposes, we only use aggregated data, such as numbers of followers, number of interactions (likes, comments, shares). We do not collect or store any other data.

 Only authorised staff of the WEB-T consortium and Communication team are involved in the social media monitoring and related communication activities.

 Before accessing the above mentioned social media platforms, users are asked to accept or decline  their respective policies. Social media users who interact with the WEB-T (for example, commenting on the WEB-T posts) do so after having agreed to the policies of those platforms.

Data comes from social media platforms and is publicly accessible. For monitoring purposes, we may collect aggregated data on users’ behaviour on social media, such as numbers of interactions or comments. 

The purpose of the processing is to facilitate online communication activities lead by the WEB-T consortium through commonly used social media platforms, and to analyse how social media users react to the activities of the WEB-T consortium and to collect feedback from WEB-T plugins users. The processing of personal data by the WEB-T consortium follows user’s voluntary registration, which is subject to the terms and conditions of a social media platform in question.

The aggregated data is used for the communication activities, such as coordinating social media presence, sending e-mails and invitations (this entails the management of contact lists for correspondence), statistical and analytical purposes, as well as the promotion of the WEB-T consortium communication campaigns and related activities. That can be achieved through:

• Engaging: interacting with social media users and responding to their queries;
• Advertising: raising awareness about the WEB-T plugin use and how WEB-T can help to manage multilingual communication on the users Websites.
• Reporting and optimisation: analysing performance of posts and improving WEB-T consortium online communication and engagement on social media.

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

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 institution or body (Article 5(1)(a) of Regulation (EU) 2018/1725) 

The Data Controller only keeps your personal data for the time necessary to fulfil the purpose of collection or further processing.

Personal data derived from the user profiles and related personal data available through users’ networks and connections (including unsolicited data)

After initially being processed by the Data Controller or its processors, personal data may be stored for a maximum period of 5 (five) years or, until a user deletes a social media account. Only aggregated and numeric values for performance measurement will be stored by the Data Controller to preserve capability to provide intra-mandate reports.

Please be advised that the retention period is only an estimate and, it may vary depending on the nature of the data, why it is collected and processed, and relevant retention requirements prescribed by law.

All personal data in electronic format (e-mails, documents, databases, uploaded batches of data, etc.) are either on the servers of the European Commission (located on the premises of the Directorate-General in Brussels and in the DGDIGIT datacentre in Luxembourg), or of its contractors, all inside the EU. All processing operations are carried out pursuant to the Commission Decision (EU, Euratom) 2017/46 of 10 January 2017 on the security of communication and information systems in the Commission.

The Commission’s contractors are bound by a specific contractual clause for any processing operations of personal data on behalf of the Commission, and by the confidentiality obligations deriving from the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR).

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 personal data solely to authorised persons with a legitimate need to know for the purposes of this processing operation.

You have specific rights as a ‘data subject’ under Chapter III (Articles 14-25) of Regulation (EU) 2018/1725. As regards this processing operation, you can exercise the following rights:

• the right to access your personal data (Article 17 of Regulation (EU) 2018/1725);
• the right to rectification in the case that your personal data is inaccurate or incomplete (Article 18 of Regulation (EU) 2018/1725);
• the right to erasure of your personal data (Article 19 of Regulation (EU) 2018/1725);
• where applicable, the right to restrict the processing of your personal data (Article 20 of Regulation (EU) 2018/1725);
• the right to data portability (Article 22 of Regulation (EU) 2018/1725);
• and the right to object to the processing of your personal data, which is lawfully carried out pursuant to Article 5(1)(a).

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. The contact information can be found under Section 9.

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 for Communications Networks, Content and Technology (DG CONNECT), Directorate G Data, Unit G.3 Accessibility, Multilingualism & Safer Internet, Head of Unit at CNECT-G3ec [dot] europa [dot] eu (CNECT-G3[at]ec[dot]europa[dot]eu). 

The Data Protection Officer (DPO) of the Commission

You may contact the Data Protection Officer (DATA-PROTECTION-OFFICERec [dot] europa [dot] eu (DATA-PROTECTION-OFFICER[at]ec[dot]europa[dot]eu)) 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 (edpsedps [dot] europa [dot] eu (edps[at]edps[dot]europa[dot]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.

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.

European Commission social media policy: https://commission.europa.eu/about-european-commission/get-involved/social-media-connect-european-commission_en