Privacy

Data protection officer and responsible for data processing

Corporate Europe Observatory
Rue d’Édimbourg 26
1050 Brussels – Belgium
privacy@corporateeurope.org

Corporate Europe Observatory is a foundation under Dutch law. The registration number in the Netherlands at the Chamber of Commerce is 33298822. Corporate Europe Observatory is recognised by the Dutch tax office as a charitable institution (ANBI) under fiscal number 806634558. The members of the legal board (‘stichtingsbestuur’) can be found here: https://corporateeurope.org/en/who-we-are

General information on data processing

The purposes for which we process your data are:

  1. to be able to technically provide access to our database and website (for you to use our website and the online database), in which case we process your IP address and some characteristics provided by your user agent (browser). This may also include the purpose of ensuring the integrity and information security of our website and databases.

  2. to provide a contemporary and historical archive of the content of the EU lobby transparency register as kept by the EU institutions. For all registrants in the EU lobby transparency register we process the following data (as included in the register and its archives): the names of individuals affiliated to a registrant; the registrant’s postal address.

Disclosure of meta data to third parties

Users’ meta data will not be provided, or made available, to third parties for use outside of this statement, unless compelled by applicable law or a valid court order.

Use of cookies

LobbyFacts uses “has_js” which is a cookie to indicate whether or not javascript is active on the user’s computer.

LobbyFacts also uses Matomo (formerly Piwik), a software tool for statistical analysis of visitor access. Matomo, as used on LobbyFacts, respects any “do not track” settings in users’ browsers. Matomo has been configured to not use cookies for its functionality on the Lobbyfacts website. The only information which is sent to LobbyFacts’ Matomo analysis is anonymised within Matomo itself (see https://matomo.org/gdpr-analytics/) according to the settings which LobbyFacts has implemented.

Retention of the data processed by our website

The data retention period is indefinite as per the purpose of the LobbyFacts database and website.

Legal basis for the data in the LobbyFacts database

The collection of data on lobbying activities and the processing for the LobbyFacts database from EU sources is carried out on the basis of Art.6 para.1 lit.f of the General Data Protection Regulation in pursuit of a legitimate interest. The legitimate interest is the purposes of Corporate Europe Observatory to inform the public about power structures, lobby actors, and influencing strategies across the EU and beyond. Furthermore the Dutch transposition of the GDPR includes an exception for journalistic purposes (article 43 UAVG), the German transposition of the GDPR includes an exception for public archives (article 28 BDSG), and the Belgian transposition includes a similar exception in chapter V.

Building on this, we also refer to the Opinion 06/2014 on the notion of legitimate interests of the data controller under Article 7 of Directive 95/46/EC by the Article 29 Working Party (Art. 29 WP) which remains highly relevant. Its interpretation of “legitimate interest” includes “publication of data for purposes of transparency and accountability”, where the public disclosure is undertaken primarily not in the interest of the controller who publishes the data, but rather, in the interest of other stakeholders, such as employees or journalists, and the general public, to whom the data are disclosed.

Information regarding the sources of the data in the database from the EU lobby register

The data in the LobbyFacts database comes from EU sources. These data on the lobbying activities of individuals and organisations are collected via various legal bases and published by the responsible EU institutions. You can find out more about the data and its sources here.

Voluntary precautions taken by LobbyFacts

Since January 2020, the EU lobby register’s daily data files (which LobbyFacts uses to build its archive) no longer include data in the fields “Person in charge of EU relations” and “Person with legal responsibility”. In addition, where category 1 organisations (consultancies) have reported one or less than one full time equivalent lobbyist, LobbyFacts has proactively removed the office address from the published data in case it is also the registrant’s home address.

Rights of the data subject

You as a data subject have the right to access, rectify and under certain circumstances erase the data we process about you. Please bear in mind, however, that if you are a data subject of our archives of the EU lobby transparency register your right to rectification and / or erasure is far more limited under the Dutch implementing acts of the GDPR than under the GDPR itself.

Requests to access, rectify or erase your data can be directed to the Data Protection Officer above.

Right to complain

If you have a complaint about our processing of your data and / or your requests pertaining to your data, you can file a complaint with:

Autoriteit Persoonsgegevens
Postbus 93374
2509 AJ Den Haag
The Netherlands

Online complaint form: https://autoriteitpersoonsgegevens.nl/nl/zelf-doen/gebruik-uw-privacyrechten/klacht-melden-bij-de-ap

The Autoriteit Persoonsgegevens accepts correspondence in Dutch and in English.