Privacy statement for People Analytics (or 'HR Analytics')

Privacy statement for People Analytics (or 'HR Analytics')

What is our legal framework?

All personal data are processed in accordance with European Union data protection law, that is to say in line with Regulation (EU) 2018/1725 (‘EUDPR’).

Why do we process personal data?

The main purpose of processing personal data using HR Analytics is to manage HR business processes (A), which can be divided into:

operating the relevant business processes; and
designing, monitoring and evaluating the relevant business process to ensure its appropriate implementation and intended result.

For (1), aggregated data, personal data or both must be made available to the data recipients operating the process (typically managers for their staff and dedicated HR staff). The use of data is necessary to ensure effective business operations and for the ECB to fulfil its legal obligations and duty of care.

For (2), aggregated data, i.e. statistics such as averages, measures of distribution and correlations, are made available to (pre-)defined data recipients. In a few justified cases, limited personal data are shared with recipients in DG-HR for data reconciliation and data quality control, but this is not done on a large scale^[1]. In line with the requirements of data protection, by design and default, aggregated (and non-personal) data are used to gain insights into the use of HR processes and policies, which may lead to:

proposals for new policies or policy changes;
improvement of processes and instruments for the policy implementation; or
communication campaigns to the ECB community or other measures to increase the policy adoption or implementation.

Designing, monitoring and evaluating business processes also involves making aggregated non-personal data available to selected stakeholders, including staff and staff representatives (who are in most cases also data subjects).

In addition to managing business processes, the sharing of personal data or the processing of personal data to share aggregated and non-personal data with ECB-external data recipients to comply with applicable regulations is another purpose (B).

The purposes above are linked to the services HR Analytics offers and further specified in the table below.

Table 1: Links between services and the related processing activities' respective general purposes

#	Purpose	Analysis and recommendations	Data and analytics products	On-demand reporting
A.1	Operating business processes	n/a	Providing the data point(s) and statistics to data recipients who operate the regular processes (e.g. the annual salary and bonus review ‒ ASBR) or on a day-to-day basis (e.g. on positions) Enabling structured data input (e.g. for `Strategic Workforce Planning`) Supporting operational business decisions (e.g. providing decision support for yearly rotation of staff between Joint Supervisory Teams)	Providing the data point(s) and statistics to data recipients who operate the regular processes (e.g. monitoring compliance with maximum contract duration) or on a day-to-day basis when requested (e.g. for overtime) Supporting operational business decisions
A.2	Designing, monitoring and evaluating the relevant business process	Preparing (aggregated) statistics which allow strategic business decisions (e.g. changing a policy) or tactical decisions (e.g. reacting to a short to mid-term issue like high overtime statistics) to be taken Supporting the testing of business hypotheses and communication about HR issues based on (aggregated) statistics (e.g. validating statements by staff, staff representation or HR about HR issues like an increasing share of temporary staff, higher promotion rates for certain demographics, etc.)	Providing data and statistics that allow an HR policy or business process to be monitored and assessed Providing projected aggregated data and statistics for tactical and strategic decision-making Providing insights based on aggregated data from predictive analysis or forecasts Providing aggregated statistics for creating transparency^[2]	Providing data point(s) and statistics to support policy and process assessment and design
B	Data shared with ECB-external data recipients	n/a	Providing aggregated and non-personal statistics to comply with legislation and create transparency	Providing aggregated and non-personal statistics to comply with legislation and create transparency Provide personal data for compliance reasons with national governments

What is the legal basis for the ECB processing your personal data?

The processing by HR Analytics is necessary for the performance of ECB tasks carried out in the public interest (Article 5(1), point (a), of the EUDPR. Article 127(2) and 127(5) of the Treaty on the Functioning of the European Union (TFEU) establish the basic tasks. In addition, Protocol No 4 to the TFEU reiterates the tasks of the European System of Central Banks and of the European Central Bank (ESCB) in Article 3, and further specifies in Article 11.6 that “[t]he Executive Board shall be responsible for the current business of the ECB”.

In discharging its responsibilities with regard to the management of the ECB’s current business, including the sound and effective management of human resources, the Executive Board (EB) adopts decisions that are implemented by the Directorate General Human Resources (DG-HR) and the people managers in the business areas. The employment relationship between the ECB and its staff is governed by the Conditions of Employment for Staff of the ECB as adopted by the Governing Council on a proposal from the EB (Article 36 of Protocol No 4) and further implemented by the Staff Rules as adopted by the EB.

In addition, DG-HR has been vested with the tasks mentioned above as enshrined in the ECB Functions Paper, following a decision by the EB, in the context of the implementation of the ECB’s employment legal framework. This constitutes the general legal basis for the processing of personal data by HR Analytics, in accordance with Article 5(1), point (a), of the EUDPR.

In addition, the EB has adopted “Human Resources Management” as item C12.1 in the Eurosystem Functions Grid and distributed the responsibilities as follows according to the ECB Functions Paper:

“For all ECB staff, DG-HR offers a strategic partnership to the ECB business areas and up-to-date services that underpin sustainable organisational excellence as well as a healthy work environment fostering people engagement and personal growth. For this purpose, it develops and maintains all relevant human resources policies, processes and instruments, and provides expert, customised advice on their effective implementation.” (p. 50)

The Functions Paper underpins that the ECB sees HR Analytics as a clear HR responsibility and, more specifically, as a responsibility of the Employee Services Division:

“supports the development of HR metrics and analytics.” (p. 51)

The following overview provides more detailed references to the ECB Functions Paper, the ECB Staff Rules and the Conditions of Employment for Staff of the ECB as specific legal bases, read in conjunction with Article 5(1), point (a), of the EUDPR, with regard to the data processing which is necessary to effectively manage the organisational responsibilities of the ECB.

1. Dashboards and reports related to leave

Specific legal basis:

Regarding annual leave: Article 5.7 (annual leave) of the ECB Staff Rules read in conjunction with Article 27 of the Conditions of Employment for Staff of the ECB; Article 5.6 (annual leave) of the ECB Rules for Short-term Employment read in conjunction with Article 26 of the Conditions of Short-Term Employment for Staff of the ECB; Article 9(2) (attendance and absences) of Decision ECB/2015/NP13 (rules governing the traineeship programme of the ECB)
Regarding recuperation days: Article 5.1.9.2 of the ECB Staff Rules read in conjunction with Article 25 of the Conditions of Employment for Staff of the ECB; Article 5.1.9.2 of the ECB Rules for Short-term Employment read in conjunction with Article 23 of the Conditions of Short-Term Employment for Staff of the ECB
Regarding compensatory leave for overtime: Article 5.3.4(c) of the ECB Staff Rules read in conjunction with Article 26(a) of the Conditions of Employment for Staff of the ECB; Article 5.2.4(c) of the ECB Rules for Short-term Employment read in conjunction with Article 24(b) of the Conditions of Short-Term Employment for Staff of the ECB
Regarding special leave: Articles 5.10.1, 5.10.2, 5.10.3, 5.10.4, 5.10.5, 5.10.6, 5.10.7 of the ECB Staff Rules read in conjunction with Article 28(iii) of the Conditions of Employment for Staff of the ECB; Articles 5.9.1, 5.9.2, 5.9.3, 5.9.4, 5.9.5, 5.9.6, 5.9.7 of the ECB Rules for Short-term Employment read in conjunction with Article 27(iii) of the Conditions of Short-Term Employment for Staff of the ECB
Regarding unpaid parental leave: Article 5.11.1 of the ECB Staff Rules read in conjunction with Article 29 of the Conditions of Employment for Staff of the ECB
Regarding unpaid leave: Articles 5.12.1, 5.12.1a and 5.12.1b of the ECB Staff Rules read in conjunction with Article 30 of the Conditions of Employment for Staff of the ECB
Regarding teleworking: Article 5.1bis.4 (quota and place of teleworking) of the ECB Staff Rules read in conjunction with Article 25 of the Conditions of Employment for Staff of the ECB; Article 5.1bis (teleworking) of the ECB Rules for Short-term Employment read in conjunction with Article 23(b) of the Conditions of Short-Term Employment for Staff of the ECB; Article 9a(6) of Decision ECB/2015/NP13 (rules governing the traineeship programme of the ECB)
Regarding overtime work: Article 5.3.2 of the ECB Staff Rules read in conjunction with Article 26(a) of the Conditions of Employment for Staff of the ECB; Article 5.2.2 of the ECB Rules for Short-term Employment read in conjunction with Article 24(a) of the Conditions of Short-Term Employment for Staff of the ECB
Regarding age: Article 38 (pension) of the Conditions of Employment for Staff of the ECB
Regarding gender: Article 5.9 (maternity and adoptive leave) of the ECB Staff Rules read in conjunction with Article 28(i) and (ii) of the Conditions of Employment for Staff of the ECB; Article 5.8 (maternity and adoptive leave) of the ECB Rules for Short-term Employment read in conjunction with Article 27(i) and (ii) of the Conditions of Short-Term Employment for Staff of the ECB
Regarding employment relations: Article 9(a) and (b) of the Conditions of Employment for Staff of the ECB; Article 2.0 (conversion of contracts for a definite period) of the ECB Staff Rules read in conjunction with Article 10(c) of the Conditions of Employment for Staff of the ECB; Article 2.0a (conditions for non-convertible fixed-term contracts and successive contracts) of the ECB Staff Rules read in conjunction with Article 10(d) of the Conditions of Employment for Staff of the ECB; Article 2.2 (termination of contract) of the ECB Staff Rules read in conjunction with Article 11 of the Conditions of Employment for Staff of the ECB
Regarding working time: Articles 5.2.1 and 5.2.2 of the ECB Staff Rules read in conjunction with Article 25 of the Conditions of Employment for Staff of the ECB; Articles 5.11.1 and 5.11.2 of the ECB Rules for Short-term Employment read in conjunction with Article 23(a) of the Conditions of Short-Term Employment for Staff of the ECB
Regarding compensation data: Article 3.1.4 of the ECB Staff Rules read in conjunction with Article 12 of the Conditions of Employment for Staff of the ECB

We consider that the requirements set out in Article 6 of the EUDPR are met and that the processing is compatible with the purpose for which the personal data have been initially collected, taking into account the following:

While the data have been collected for the purpose of ensuring that staff and trainees can effectively exercise their contractual rights and obligations related to leave, the processing by HR Analytics amounts to processing for another purpose which is compatible with the original one. Providing personal data about leave to managers and their HR support (purposes (i) and (ii)), and ensuring that leave policies and HR services related to wellbeing are up to date (purpose (iii)) are linked with the initial purpose for which the data has been collected. The data has been collected and further processed in the context of employment and the relationship between the data subject and controller has not changed. Incidentally, special categories of personal data, i.e. administrative sick leave data (limited to start and end date of “SickWithoutCertificate”, “SickPendingCertificate”, “SickLeave”, “Long-term sick leave”) and maternity leave data are processed. However, this data is removed in the first data preparation steps. As the aggregated data are used to analyse and adapt HR policies and services, there are no direct consequences of the further processing for data subjects. Due process would be followed in respect of the making of any change in HR policies and services, including specific safeguards for the rights of individuals (such as consultations with staff representatives and the Data Protection Officer (DPO)). Finally, the data is pseudonymised in the first data preparation steps and the statistics are aggregated at institutional and business area level.

2. Analyses and insights related to periods of leave (excluding sick leave)

Specific legal basis:

Regarding annual leave: Article 5.7 (annual leave) of the ECB Staff Rules read in conjunction with Article 27 of the Conditions of Employment for Staff of the ECB; Article 5.6 (annual leave) of the ECB Rules for Short-term Employment read in conjunction with Article 26 of the Conditions of Short-Term Employment for Staff of the ECB; Article 9(2) (attendance and absences) of Decision ECB/2015/NP13 (rules governing the traineeship programme of the ECB
Regarding recuperation days: Article 5.1.9.2 of the ECB Staff Rules read in conjunction with Article 25 of the Conditions of Employment for Staff of the ECB; Article 5.1.9.2 of the ECB Rules for Short-term Employment read in conjunction with Article 23 of the Conditions of Short-Term Employment for Staff of the ECB
Regarding compensatory leave for overtime: Article 5.3.4(c) of the ECB Staff Rules read in conjunction with Article 26(a) of the Conditions of Employment for Staff of the ECB; Article 5.2.4(c) of the ECB Rules for Short-term Employment read in conjunction with Article 24(b) of the Conditions of Short-Term Employment for Staff of the ECB
Regarding special leave: Articles 5.10.1, 5.10.2, 5.10.3, 5.10.4, 5.10.5, 5.10.6, 5.10.7 of the ECB Staff Rules read in conjunction with Article 28(iii) of the Conditions of Employment for Staff of the ECB; Articles 5.9.1, 5.9.2, 5.9.3, 5.9.4, 5.9.5, 5.9.6, 5.9.7 of the ECB Rules for Short-term Employment read in conjunction with Article 27(iii) of the Conditions of Short-Term Employment for Staff of the ECB
Regarding unpaid parental leave: Article 5.11.1 of the ECB Staff Rules read in conjunction with Article 29 of the Conditions of Employment for Staff of the ECB
Regarding unpaid leave: Articles 5.12.1, 5.12.1a and 5.12.1b of the ECB Staff Rules read in conjunction with Article 30 of the Conditions of Employment for Staff of the ECB
Regarding teleworking: Article 5.1bis.4 (quota and place of teleworking) of the ECB Staff Rules read in conjunction with Article 25 of the Conditions of Employment for Staff of the ECB; Article 5.1bis (teleworking) of the ECB Rules for Short-term Employment read in conjunction with Article 23(b) of the Conditions of Short-Term Employment for Staff of the ECB; Article 9a(6) of Decision ECB/2015/NP13 (rules governing the traineeship programme of the ECB)
Regarding overtime work: Article 5.3.2 of the ECB Staff Rules read in conjunction with Article 26(a) of the Conditions of Employment for Staff of the ECB; Article 5.2.2 of the ECB Rules for Short-term Employment read in conjunction with Article 24(a) of the Conditions of Short-Term Employment for Staff of the ECB
Regarding age: Article 38 (pension) of the Conditions of Employment for Staff of the ECB
Regarding gender: Article 5.9 (maternity and adoptive leave) of the ECB Staff Rules read in conjunction with Article 28(i) and (ii) of the Conditions of Employment for Staff of the ECB; Article 5.8 (maternity and adoptive leave) of the ECB Rules for Short-term Employment read in conjunction with Article 27(i) and (ii) of the Conditions of Short-Term Employment for Staff of the ECB
Regarding employment relations: Article 9(a) and (b) of the Conditions of Employment for Staff of the ECB; Article 2.0 (conversion of contracts for a definite period) of the ECB Staff Rules read in conjunction with Article 10(c) of the Conditions of Employment for Staff of the ECB; Article 2.0a (conditions for non-convertible fixed-term contracts and successive contracts) of the ECB Staff Rules read in conjunction with Article 10(d) of the Conditions of Employment for Staff of the ECB; Article 2.2 (termination of contract) of the ECB Staff Rules read in conjunction with Article 11 of the Conditions of Employment for Staff of the ECB
Regarding working time: Articles 5.2.1 and 5.2.2 of the ECB Staff Rules read in conjunction with Article 25 of the Conditions of Employment for Staff of the ECB; Articles 5.11.1 and 5.11.2 of the ECB Rules for Short-term Employment read in conjunction with Article 23(a) of the Conditions of Short-Term Employment for Staff of the ECB
Regarding compensation data: Article 3.1.4 of the ECB Staff Rules read in conjunction with Article 12 of the Conditions of Employment for Staff of the ECB
Regarding parenthood: Article 5.10.1, subparagraphs (c), (ca), (cb) and (cc), of the ECB Staff Rules read in conjunction with Article 28(iii) of the Conditions of Employment for Staff of the ECB; Article 5.9.1, subparagraphs (c), (ca), (cb) and (cc), of the ECB Rules for Short-term Employment read in conjunction with Article 27(iii) of the Conditions of Short-Term Employment for Staff of the ECB

We consider that the requirements set out in Article 6 of the EUDPR are met and that the processing is compatible with the purpose for which the personal data have been initially collected, taking into account the following:

While the data have been collected for the purpose of ensuring that staff and trainees can effectively exercise their contractual rights and obligations related to leave, the production of statistics regarding absences amounts to processing for another purpose which is compatible with the original one. Ensuring that leave policies and HR services related to wellbeing are up to date is linked with the initial purpose for which the data has been collected. The data has been collected and further processed in the context of employment and the relationship between the data subject and controller has not changed. Incidentally, in the interim stage, special categories of personal data, i.e. administrative sick leave data (limited to start and end date of “SickWithoutCertificate”, “SickPendingCertificate”, “SickLeave”, “Long-term sick leave”) and maternity leave data are processed. However, these data are removed in the first data preparation steps. As the statistics are used to analyse and adapt HR policies and services, there are no direct consequences of the further processing for data subjects. Due process would be followed in respect of the making of any change in HR policies and services, including specific safeguards for the rights of individuals (such as consultations with staff representatives and the DPO). Finally, the data is pseudonymised in the first data preparation step and the statistics are aggregated at institutional and business area level.

3. Dashboards and reports as well as analyses and insights related to sick leave

Specific legal basis:

The administrative sick leave data may be considered as a special category related to health and is processed in accordance with Article 10(2), point (b), of the EUDPR
Regarding sick leave: Article 5.13 (sick leave) of the ECB Staff Rules read in conjunction with Article 31 of the Conditions of Employment for Staff of the ECB, Article 9(3) of Decision ECB/2015/NP13 (rules governing the traineeship programme of the ECB), and Article 5.10 of the ECB Rules on Short-term Employment, in conjunction Article 28 of the Conditions of Short-term Employment for Staff of the ECB
Regarding employment relations: Article 9(a) and (b) of the Conditions of Employment for Staff of the ECB; Article 2.0 (conversion of contracts for a definite period) of the ECB Staff Rules read in conjunction with Article 10(c) of the Conditions of Employment for Staff of the ECB; Article 2.0a (conditions for non-convertible fixed-term contracts and successive contracts) of the ECB Staff Rules read in conjunction with Article 10(d) of the Conditions of Employment for Staff of the ECB
Regarding compensation data: Article 3.1.4 of the ECB Staff Rules read in conjunction with Article 12 of the Conditions of Employment for Staff of the ECB
Regarding age: Article 38 (pension) of the Conditions of Employment for Staff of the ECB
Regarding working time: Articles 5.2.1 and 5.2.2 of the ECB Staff Rules read in conjunction with Article 25 of the Conditions of Employment for Staff of the ECB; Articles 5.11.1 and 5.11.2 of the ECB Rules for Short-term Employment read in conjunction with Article 23(a) of the Conditions of Short-Term Employment for Staff of the ECB
Regarding parenthood: Article 3.6 of the ECB Staff Rules read in conjunction with Article 16 of the Conditions of Employment for Staff of the ECB, Article 5.10.1, subparagraphs (c) and (cc), of the ECB Staff Rules read in conjunction with Article 28(iii) of the Conditions of Employment for Staff of the ECB;

We consider that the requirements set out in Article 6 of the EUDPR are met and that the further processing is compatible with the initial purpose for which the data has been collected, taking into account the following:

While the data have been collected for the purpose of ensuring that staff and trainees can effectively exercise their contractual rights and obligations, the processing by HR Analytics amounts to processing for another purpose which is compatible with the original one. Managing wellbeing, supporting reintegration after long-term sick leave, supporting staff to submit sick leave certificates (purpose (i)) and ensuring that sick leave policies and HR services related to wellbeing are up to date (purpose (iii)) are linked with the initial purpose for which the data has been collected. The data has been collected and further processed in the context of employment and the relationship between the data subject and controller has not changed. Special categories of data related to health are processed pursuant to Article 10(2), point (b), of the EUDPR. There are no direct consequences of further processing for data subjects. Due process would be followed in respect of the making of any change with any consequences for the data subjects, including specific safeguards for the rights of individuals (including but not limited to consultations with staff representatives, the DPO and European Data Protection Supervisor (EDPS) as needed). Finally, the statistics are aggregated at institutional and business area level and there is no risk of identifying individuals or drawing conclusions about private lives.

4. Dashboards and reports as well as analyses and insights related to working time and attendances

Specific legal basis:

Regarding annual leave: Article 5.7 (annual leave) of the ECB Staff Rules read in conjunction with Article 27 of the Conditions of Employment for Staff of the ECB; Article 5.6 (annual leave) of the ECB Rules for Short-term Employment read in conjunction with Article 26 of the Conditions of Short-Term Employment for Staff of the ECB; Article 9(2) (attendance and absences) of Decision ECB/2015/NP13 (rules governing the traineeship programme of the ECB)
Regarding recuperation days: Article 5.1.9.2 of the ECB Staff Rules read in conjunction with Article 25 of the Conditions of Employment for Staff of the ECB; Article 5.1.9.2 of the ECB Rules for Short-term Employment read in conjunction with Article 23 of the Conditions of Short-Term Employment for Staff of the ECB
Regarding compensatory leave for overtime: Article 5.3.4(c) of the ECB Staff Rules read in conjunction with Article 26(a) of the Conditions of Employment for Staff of the ECB; Article 5.2.4(c) of the ECB Rules for Short-term Employment read in conjunction with Article 24(b) of the Conditions of Short-Term Employment for Staff of the ECB
Regarding special leave: Articles 5.10.1, 5.10.2, 5.10.3, 5.10.4, 5.10.5, 5.10.6, 5.10.7 of the ECB Staff Rules read in conjunction with Article 28(iii) of the Conditions of Employment for Staff of the ECB; Articles 5.9.1, 5.9.2, 5.9.3, 5.9.4, 5.9.5, 5.9.6, 5.9.7 of the ECB Rules for Short-term Employment read in conjunction with Article 27(iii) of the Conditions of Short-Term Employment for Staff of the ECB
Regarding unpaid parental leave: Article 5.11.1 of the ECB Staff Rules read in conjunction with Article 29 of the Conditions of Employment for Staff of the ECB
Regarding unpaid leave: Articles 5.12.1, 5.12.1a and 5.12.1b of the ECB Staff Rules read in conjunction with Article 30 of the Conditions of Employment for Staff of the ECB
Regarding teleworking: Article 5.1bis.4 (quota and place of teleworking) of the ECB Staff Rules read in conjunction with Article 25 of the Conditions of Employment for Staff of the ECB; Article 5.1bis (teleworking) of the ECB Rules for Short-term Employment read in conjunction with Article 23(b) of the Conditions of Short-Term Employment for Staff of the ECB; Article 9a(6) of Decision ECB/2015/NP13 (rules governing the traineeship programme of the ECB)
Regarding overtime work: Article 5.3.2 of the ECB Staff Rules read in conjunction with Article 26(a) of the Conditions of Employment for Staff of the ECB; Article 5.2.2 of the ECB Rules for Short-term Employment read in conjunction with Article 24(a) of the Conditions of Short-Term Employment for Staff of the ECB
Regarding shift work: Article 5.5 (shift work duties) of the ECB Staff Rules read in conjunction with Article 26(b) of the Conditions of Employment for Staff of the ECB; Article 5.4 (shift work duties) of the ECB Rules for Short-term Employment read in conjunction with Article 25 of the Conditions of Short-Term Employment for Staff of the ECB
Regarding sick leave: Article 5.13 (sick leave) of the ECB Staff Rules read in conjunction with Article 31 of the Conditions of Employment for Staff of the ECB, Article 9(3) of Decision ECB/2015/NP13 (rules governing the traineeship programme of the ECB), and Article 5.10 of the ECB Rules on Short-term Employment, read in conjunction with Article 28 of the Conditions of Short-term Employment for Staff of the ECB. These are processed in accordance with Article 10(2), point (b), of the EUDPR
Regarding age: Article 38 (pension) of the Conditions of Employment for Staff of the ECB
Regarding gender: Article 5.9 (maternity and adoptive leave) of the ECB Staff Rules read in conjunction with Article 28(i) and (ii) of the Conditions of Employment for Staff of the ECB; Article 5.8 (maternity and adoptive leave) of the ECB Rules for Short-term Employment read in conjunction with Article 27(i) and (ii) of the Conditions of Short-Term Employment for Staff of the ECB
Regarding employment relations: Article 9(a) and (b) of the Conditions of Employment for Staff of the ECB; Article 2.0 (conversion of contracts for a definite period) of the ECB Staff Rules read in conjunction with Article 10(c) of the Conditions of Employment for Staff of the ECB; Article 2.0a (conditions for non-convertible fixed-term contracts and successive contracts) of the ECB Staff Rules read in conjunction with Article 10(d) of the Conditions of Employment for Staff of the ECB; Article 2.2 (termination of contract) of the ECB Staff Rules read in conjunction with Article 11 of the Conditions of Employment for Staff of the ECB
Regarding working time: Articles 5.2.1 and 5.2.2 of the ECB Staff Rules read in conjunction with Article 25 of the Conditions of Employment for Staff of the ECB; Articles 5.11.1 and 5.11.2 of the ECB Rules for Short-term Employment read in conjunction with Article 23(a) of the Conditions of Short-Term Employment for Staff of the ECB
Regarding compensation data: Article 3.1.4 of the ECB Staff Rules read in conjunction with Article 12 of the Conditions of Employment for Staff of the ECB
Regarding parenthood: Article 5.10.1, subparagraphs (ca), (cb) and (cc), of the ECB Staff Rules read in conjunction with Article 28(iii) of the Conditions of Employment for Staff of the ECB; Article 5.9.1, subparagraphs (c), (ca), (cb) and (cc), of the ECB Rules for Short-term Employment read in conjunction with Article 27(iii) of the Conditions of Short-Term Employment for Staff of the ECB

We consider that the requirements set out in Article 6 of the EUDPR are met and that the processing is compatible with the purpose for which the personal data have been initially collected, taking into account the following:

While the data have been collected for the purpose of ensuring that staff and trainees can effectively exercise their contractual rights and obligations related to working time and attendances, the processing by HR Analytics amounts to processing for another purpose which is compatible with the original one. Managing wellbeing (purpose (i)), supporting managers to do so (purpose (ii)) and ensuring that HR policies and services related to working time and attendances are up to date (purpose (iii)) are linked with the initial purpose for which the data has been collected. The data has been collected and further processed in the context of employment and the relationship between the data subject and controller has not changed. Special categories of data related to health are processed pursuant to Article 10(2), point (b), of the EUDPR. There are no direct consequences of the further processing for data subjects. Due process would be followed in respect of the making of any change in HR policies and services, including specific safeguards for the rights of individuals (such as consultations with staff representatives and the DPO). Finally, for purpose (iii), the data is pseudonymised in the first data preparation step and the statistics are aggregated at institutional and business area level.

5. Dashboards and reports as well as analyses and insights related to positions, contracts, and employment

Specific legal basis:

Regarding employment relations: Article 9(a) and (b) of the Conditions of Employment for Staff of the ECB; Article 2.0 (conversion of contracts for a definite period) of the ECB Staff Rules read in conjunction with Article 10(c) of the Conditions of Employment for Staff of the ECB; Article 2.0a (conditions for non-convertible fixed-term contracts and successive contracts) of the ECB Staff Rules read in conjunction with Article 10(d) of the Conditions of Employment for Staff of the ECB; Article 2.2 (termination of contract) of the ECB Staff Rules read in conjunction with Article 11 of the Conditions of Employment for Staff of the ECB
Regarding unpaid parental leave: Article 5.11.1 of the ECB Staff Rules read in conjunction with Article 29 of the Conditions of Employment for Staff of the ECB
Regarding unpaid leave: Articles 5.12.1, 5.12.1a and 5.12.1b of the ECB Staff Rules read in conjunction with Article 30 of the Conditions of Employment for Staff of the ECB
Regarding long-term sick leave (i.e. sick leave uninterrupted for more than six weeks): Article 5.13.2 (sick leave) of the ECB Staff Rules read in conjunction with Article 31 of the Conditions of Employment for Staff of the ECB; Article 5.10.2 (sick leave) of the ECB Staff Rules read in conjunction with Article 28 of the Conditions of Employment for Staff of the ECB; Article 9(3) (attendances and absences) of Decision ECB/2015/NP13 (rules governing the traineeship programme of the ECB)
Regarding age: Article 38 (pension) of the Conditions of Employment for Staff of the ECB
Regarding gender: Article 5.9 (maternity and adoptive leave) of the ECB Staff Rules read in conjunction with Article 28(i) and (ii) of the Conditions of Employment for Staff of the ECB; Article 5.8 (maternity and adoptive leave) of the ECB Rules for Short-term Employment read in conjunction with Article 27(i) and (ii) of the Conditions of Short-Term Employment for Staff of the ECB
Regarding compensation data: Article 3.1.4 of the ECB Staff Rules read in conjunction with Article 12 of the Conditions of Employment for Staff of the ECB

We consider that the requirements set out in Article 6 of the EUDPR are met and that the processing is compatible with the purpose for which the personal data have been initially collected, taking into account the following:

While the personal data have been collected for the purpose of managing employment relations, the production of statistics regarding contracts and positions amounts to processing for another purpose which is compatible with the original one. Resource planning (purpose (i)) and providing advice thereof (purpose (ii)), organising farewell surveys (purpose (iii)), managing employment contracts (purpose (iv)), and ensuring that the ECB policies and HR services related to resources planning and contract management are up to date (purpose (v)) are linked with the initial purpose for which the data has been collected. The data that has been collected and further processed in the context of the employment and the relationship between the data subject and controller has not changed. In the interim stage, categories of data which may be considered as special categories, i.e. administrative data about long-term sick leave (limited to start and end date of that type of absence), are processed. This is necessary because employment contracts may be issued with a view to cover the long-term absence of a member of staff who holds a permanent position. The data is limited to what is necessary, i.e. the start and end date of long-term sick leave. While administrative data regarding long-term sick leave may be considered a special category concerning health, it is processed in accordance with Article 10(2), point (b), of the EUDPR. There are no direct consequences of the further processing for data subjects. Due process would be followed in respect of any consequences for data subjects, including specific safeguards for the rights of individuals (such as consultations with staff representatives and the DPO). Finally, for purpose (v), the data is pseudonymised in the first data preparation step and the statistics are aggregated at institutional and business area level.

6. Dashboards and reports as well as analyses and insights related to the organisation and role profiles

Specific legal basis:

Regarding employment relations: Article 9(a) and (b) of the Conditions of Employment for Staff of the ECB; Article 2.0 (conversion of contracts for a definite period) of the ECB Staff Rules read in conjunction with Article 10(c) of the Conditions of Employment for Staff of the ECB; Article 2.0a (conditions for non-convertible fixed-term contracts and successive contracts) of the ECB Staff Rules read in conjunction with Article 10(d) of the Conditions of Employment for Staff of the ECB; Article 2.2 (termination of contract) of the ECB Staff Rules read in conjunction with Article 11 of the Conditions of Employment for Staff of the ECB
Regarding age: Article 38 (pension) of the Conditions of Employment for Staff of the ECB
Regarding gender: Article 5.9 (maternity and adoptive leave) of the ECB Staff Rules read in conjunction with Article 28(i) and (ii) of the Conditions of Employment for Staff of the ECB; Article 5.8 (maternity and adoptive leave) of the ECB Rules for Short-term Employment read in conjunction with Article 27(i) and (ii) of the Conditions of Short-Term Employment for Staff of the ECB
Regarding compensation data: Article 3.1.4 of the ECB Staff Rules read in conjunction with Article 12 of the Conditions of Employment for Staff of the ECB
Regarding parenthood: Article 5.10.1, subparagraphs (ca), (cb) and (cc), of the ECB Staff Rules read in conjunction with Article 28(iii) of the Conditions of Employment for Staff of the ECB; Article 5.9.1, subparagraphs (c), (ca), (cb) and (cc), of the ECB Rules for Short-term Employment read in conjunction with Article 27(iii) of the Conditions of Short-Term Employment for Staff of the ECB

We consider that the requirements set out in Article 6 of the EUDPR are met and that the processing is compatible with the purpose for which the personal data have been initially collected, taking into account the following:

While the personal data have been collected for the purpose of managing contracts, the processing by HR Analytics amounts to processing for another purpose which is compatible with the original one. Resource planning (purpose (i)) and ensuring that the HR policies related to organisational design, position management and role profiles are up to date (purpose (ii)) are linked with the initial purpose for which the data has been collected. The data has been collected and further processed in the context of employment and the relationship between the data subject and controller has not changed. There are no direct consequences of the further processing for data subjects. Due process would be followed in respect of any consequence, including specific safeguards for the rights of individuals (such as consultations with staff representatives and the DPO). Finally, for purpose (ii), the data is pseudonymised in the first data preparation step and the statistics are aggregated at institutional and business area level.

7. Position Plan simulation tool

Specific legal basis:

Regarding employment relations: Article 9(a) and (b) of the Conditions of Employment for Staff of the ECB; Article 2.0 (conversion of contracts for a definite period) of the ECB Staff Rules read in conjunction with Article 10(c) of the Conditions of Employment for Staff of the ECB; Article 2.0a (conditions for non-convertible fixed-term contracts and successive contracts) of the ECB Staff Rules read in conjunction with Article 10(d) of the Conditions of Employment for Staff of the ECB; Article 2.2 (termination of contract) of the ECB Staff Rules read in conjunction with Article 11 of the Conditions of Employment for Staff of the ECB
Regarding age: Article 38 (pension) of the Conditions of Employment for Staff of the ECB
Regarding gender: Article 5.9 (maternity and adoptive leave) of the ECB Staff Rules read in conjunction with Article 28(i) and (ii) of the Conditions of Employment for Staff of the ECB; Article 5.8 (maternity and adoptive leave) of the ECB Rules for Short-term Employment read in conjunction with Article 27(i) and (ii) of the Conditions of Short-Term Employment for Staff of the ECB
Regarding compensation data: Article 3.1.4 of the ECB Staff Rules read in conjunction with Article 12 of the Conditions of Employment for Staff of the ECB

We consider that the requirements set out in Article 6 of the EUDPR are met and that the processing is compatible with the purpose for which the personal data have been initially collected, taking into account the following:

While the personal data have been collected for the purpose of managing employment contracts, the processing by HR Analytics amounts to processing for another purpose which is compatible with the original one. Resource planning (purpose (i)) and supporting managers in respect of resource planning (purpose (ii)) are linked with the initial purpose for which the data has been collected. The data has been collected and further processed in the context of employment and the relationship between the data subject and controller has not changed. There are no direct consequences of the further processing for data subjects. Due process would be followed in respect of any consequence, including specific safeguards for the rights of individuals (such as consultations with staff representatives and the DPO).

8. Strategic Workforce Planning (SWFP) tool

Specific legal basis:

Regarding employment relations: Article 9(a) and (b) of the Conditions of Employment for Staff of the ECB; Article 2.0 (conversion of contracts for a definite period) of the ECB Staff Rules read in conjunction with Article 10(c) of the Conditions of Employment for Staff of the ECB; Article 2.0a (conditions for non-convertible fixed-term contracts and successive contracts) of the ECB Staff Rules read in conjunction with Article 10(d) of the Conditions of Employment for Staff of the ECB; Article 2.2 (termination of contract) of the ECB Staff Rules read in conjunction with Article 11 of the Conditions of Employment for Staff of the ECB
Regarding the ASBR: Article 5 of Annex I (salary structure) of the Conditions of Employment for Staff of the ECB and the Annual Salary & Bonus Review (ASBR) Guidelines as adopted by the Executive Board (SEC/EB/20/1171/14a)
Regarding promotion without recruitment: Articles 2a.11.1 (eligibility for the promotion procedure) and 2a.11.8 (promotion decision) of the ECB Staff Rules
Regarding age: Article 38 (pension) of the Conditions of Employment for Staff of the ECB
Regarding gender: Article 5.9 (maternity and adoptive leave) of the ECB Staff Rules read in conjunction with Article 28(i) and (ii) of the Conditions of Employment for Staff of the ECB; Article 5.8 (maternity and adoptive leave) of the ECB Rules for Short-term Employment read in conjunction with Article 27(i) and (ii) of the Conditions of Short-Term Employment for Staff of the ECB

We consider that the requirements set out in Article 6 of the EUDPR are met and that the processing is compatible with the purpose for which the personal data have been initially collected, taking into account the following:

While the personal data have been collected for the purpose of managing employment relations, the processing by HR Analytics amounts to processing for another purpose which is compatible with the original one. Ensuring that the ECB can effectively organise and plan ahead for the workforce is linked with the initial purpose for which the data has been collected. The data that has been collected and further processed in the context of the employment and the relationship between the data subject and controller has not changed. As the aggregated data are used to plan workforce, there are no direct consequences of the further processing for data subjects. Any eventual decision impacting individuals would follow due process, including the specific safeguards for the rights of individuals.

9. SSM rotation tool

Specific legal basis:

Articles 3 to 6 of Regulation 468/2014 of the European Central Bank (ECB/2014/17)
Regarding employment relations: Article 9(a) and (b) of the Conditions of Employment for Staff of the ECB; Article 2.0 (conversion of contracts for a definite period) of the ECB Staff Rules read in conjunction with Article 10(c) of the Conditions of Employment for Staff of the ECB; Article 2.0a (conditions for non-convertible fixed-term contracts and successive contracts) of the ECB Staff Rules read in conjunction with Article 10(d) of the Conditions of Employment for Staff of the ECB; Article 2.2 (termination of contract) of the ECB Staff Rules read in conjunction with Article 11 of the Conditions of Employment for Staff of the ECB
Regarding compensation data: Article 3.1.4 of the ECB Staff Rules read in conjunction with Article 12 of the Conditions of Employment for Staff of the ECB

10. Dashboards and reports as well as analyses and insights related to demographics and diversity

Specific legal basis:

For purposes (v) and (vi), Article 5(1), point (b), of the EUDPR is applicable
Regarding employment relations: Article 9(a) and (b) of the Conditions of Employment for Staff of the ECB; Article 2.0 (conversion of contracts for a definite period) of the ECB Staff Rules read in conjunction with Article 10(c) of the Conditions of Employment for Staff of the ECB; Article 2.0a (conditions for non-convertible fixed-term contracts and successive contracts) of the ECB Staff Rules read in conjunction with Article 10(d) of the Conditions of Employment for Staff of the ECB; Article 2.2 (termination of contract) of the ECB Staff Rules read in conjunction with Article 11 of the Conditions of Employment for Staff of the ECB
Regarding EU nationality as precondition for appointment: Article 8a(a), subparagraph (i), of the Conditions of Employment for Staff of the ECB; Article 4(1), point (c), of Decision ECB/2015/NP13 (rules governing the traineeship programme of the ECB)
Regarding gender and nationality in recruitment and promotion without recruitment: Articles 1a.2.1.1 (selection and appointment) and 2a.11.2.2 (promotion to the next salary band of current position) of the ECB Staff Rules read in conjunction with Article 8a, subparagraph (c), of the Conditions of Employment for Staff of the ECB; Article 5(2) of Decision ECB/2015/NP13 (rules governing the traineeship programme of the ECB)
Regarding age: Article 38 (pension) of the Conditions of Employment for Staff of the ECB
Regarding ECB gender strategy: Executive Board Decision of 12 May 2020 on “ECB gender strategy 2020-2026” (SEC/EB/20/1148/11); Executive Board decision of 13 October 2020 on “Operationalising the ECB gender strategy 2020-2026” (SEC/EB/20/1166/15)
Regarding the transfer of data to the Federal Republic of Germany: Article 13 of the Headquarters Agreement between the ECB and the Federal Republic of Germany
Regarding the transfer of data to the governments of Union Member States: Article 15 of Protocol No 7 of the TFEU

We consider that the requirements set out in Article 6 of the EUDPR are met, taking into account the following:

While the data have been collected for the purpose of ensuring eligibility for appointment and verifying entitlement to specific benefits, the processing by HR Analytics amounts to processing for another purpose which is compatible with the original one. Managing and ensuring diversity (purposes (i) and (iv)), creating transparency regarding demographics (purpose (ii)), and ensuring that HR policies and services are up to date (purpose (iii)) are linked with the initial purpose for which the data has been collected. The data has been collected and further processed in the context of employment and the relationship between the data subject and controller has not changed. The processing does not include special categories of data. There are no consequences of the further processing for data subjects. Due process would be followed in respect of any changes for staff, including specific safeguards for the rights of individuals (including but not limited to consultations with staff representatives and the DPO as needed). Finally, for purposes (i), (ii), (iii), the data is aggregated in the first data preparation steps and the statistics are aggregated at divisional, business area and institutional level.

11. Gender pay gap analyses

Specific legal basis:

Article 157 TFEU
Article 3.5 (household allowance) of the ECB Staff Rules read in conjunction with Article 15 of the Conditions of Employment for Staff of the ECB
Article 3.6 (child allowance) of the ECB Staff Rules read in conjunction with Article 16 of the Conditions of Employment for Staff of the ECB. Categories of data concerning the health of children of staff may be considered to be special categories of data and may be processed in accordance with Article 10(2), point (b), of the EUDPR
Article 3.7 (expatriation allowance) of the ECB Staff Rules read in conjunction with Articles 17 and 18 of the Conditions of Employment for Staff of the ECB
Article 3.8 (education allowance) of the ECB Staff Rules read in conjunction with Article 19 of the Conditions of Employment for Staff of the ECB
Article 3.8bis (pre-school allowance) of the ECB Staff Rules read in conjunction with Article 19bis of the Conditions of Employment for Staff of the ECB
Article 4.3 (travel expenses) of the ECB Staff Rules read in conjunction with Articles 22(i) and 23(i) of the Conditions of Employment for Staff of the ECB
Article 4.5 (subsistence allowance) of the ECB Staff Rules read in conjunction with Article 22(ii) of the Conditions of Employment for Staff of the ECB
Article 4.6 (installation allowance) of the ECB Staff Rules read in conjunction with Article 22(iii) of the Conditions of Employment for Staff of the ECB
Article 4.7 (resettlement allowance) of the ECB Staff Rules read in conjunction with Article 23(ii) of the Conditions of Employment for Staff of the ECB
Article 6.1 (payment during sick leave and decision to grant a disability allowance) of the ECB Staff Rules read in conjunction with Article 32(a) to (c) of the Conditions of Employment for Staff of the ECB
Article 6.2a (long-term care insurance) of the ECB Staff Rules read in conjunction with Article 33a of the Conditions of Employment for Staff of the ECB
Article 6.5 (unemployment benefits) of the ECB Staff Rules read in conjunction with Article 36 of the Conditions of Employment for Staff of the ECB
Articles 2 and 5 of Annex I (salary structure) of the Conditions of Employment for Staff of the ECB
Annex III (retirement plan) of the Conditions of Employment for Staff of the ECB
Annex IIIb (retirement scheme) of the Conditions of Employment for Staff of the ECB
Articles 2, 5, 6 and 7 of Annex IV (disability benefits) of the Conditions of Employment for Staff of the ECB
Article 1a.2 of the ECB Rules on Short-term Employment
Article 4.2 (temporary accommodation) of the ECB Rules on Short-term Employment read in conjunction with Article 21(b) of the ECB Conditions for Short-term Employment

We consider that the requirements set out in Article 6 of the EUDPR are met, taking into account the following:

While the data on salaries and allowances have been collected for the purpose of ensuring the contractual rights of staff, the production of statistics and analyses regarding equal pay amounts to processing for another purpose which is compatible with the original one. Ensuring equal pay for equal work is linked with the initial purpose for which the data has been collected. The data has been collected and further processed in the context of employment and the relationship between the data subject and controller has not changed. The processing may include special categories of data related to the children of staff and is processed in accordance with Article 10(2), point (b), of the EUDPR. As the statistics are used to analyse and adapt HR policies and services, there are no direct consequences of the further processing for data subjects. Due process would be followed in respect of any change in HR policies and services, including specific safeguards for the rights of individuals (including but not limited to consultations with staff representatives and the DPO as needed). Finally, the data is pseudonymised in the data preparation step and the statistics are aggregated at institutional level.

12. Projections of the demographical development of the ECB

Specific legal basis:

Regarding age: Article 38 (pension) of the Conditions of Employment for Staff of the ECB
Annex III (retirement plan) of the Conditions of Employment for Staff of the ECB
Annex IIIb (retirement scheme) of the Conditions of Employment for Staff of the ECB
Articles 2, 5, 6 and 7 of Annex IV (disability benefits) of the Conditions of Employment for Staff of the ECB
Regarding gender in recruitment and promotion without recruitment: Articles 1a.2.1.1 (selection and appointment) and 2a.11.2.2 (promotion to the next salary band of current position) of the ECB Staff Rules read in conjunction with Article 8a, subparagraph (c), of the Conditions of Employment for Staff of the ECB
Regarding ECB gender strategy: Executive Board Decision of 12 May 2020 on “ECB gender strategy 2020-2026” (SEC/EB/20/1148/11); Executive Board decision of 13 October 2020 on “Operationalising the ECB gender strategy 2020-2026” (SEC/EB/20/1166/15)
Regarding EU nationality as precondition for appointment: Article 8a(a), subparagraph (i), of the Conditions of Employment for Staff of the ECB
Regarding employment relations: Article 9(a) and (b) of the Conditions of Employment for Staff of the ECB; Article 2.0 (conversion of contracts for a definite period) of the ECB Staff Rules read in conjunction with Article 10(c) of the Conditions of Employment for Staff of the ECB; Article 2.0a (conditions for non-convertible fixed-term contracts and successive contracts) of the ECB Staff Rules read in conjunction with Article 10(d) of the Conditions of Employment for Staff of the ECB; Article 2.2 (termination of contract) of the ECB Staff Rules read in conjunction with Article 11 of the Conditions of Employment for Staff of the ECB
Regarding compensation data: Article 3.1.4 of the ECB Staff Rules read in conjunction with Article 12 of the Conditions of Employment for Staff of the ECB
Regarding mobility: Article 2a.7 of the ECB Staff Rules read in conjunction with Article 11a of the Conditions of Employment for Staff of the ECB
Regarding promotion without recruitment: Articles 2a.11.1 (eligibility for the promotion procedure), 2a.11.8 (promotion decision) of the ECB Staff Rules
Regarding recruitment: Article 1a (selection and appointment) of the Staff Rules read in conjunction with Article 8a(b), subparagraph (i), of the Conditions of Employment for Staff of the ECB

We consider that the requirements set out in Article 6 of the EUDPR are met and that the further processing is compatible with the original purpose for which the data has been collected, taking into account the following:

Personal data has been collected for the purpose of carrying out specific rights of the data subjects and is here processed for another purpose which is compatible with the original one. Planning succession for retirees, adapting HR benefits and services to age of the employees (purpose (i)), assessing the impact of the gender strategy (purpose (ii)), projecting the distribution of staff across salary bands (purpose (iii)) and projecting the salary mass (purpose (iv)) are compatible with the initial purpose. The processing takes place in a context similar to that in which the data has been collected (i.e. HR controller), the personal data does not contain special categories of data, and the further processing has no direct consequences for the data subjects. The projections only inform the policy analysis which could potentially lead, subject to subsequent processes, to changes. Due process would be followed in respect of any change in HR policies and services, including specific safeguards for the rights of individuals (such as consultations with staff representatives and the DPO). There are appropriate safeguards in place: the data is pseudonymised at the first stage for the HR Analytics to create the model. Thereafter, the model output is kept and the personal data is deleted. In addition, statistics are aggregated at an institutional level.

13. Dashboards and reports as well as analyses and insights related to compensation and benefits

Specific legal basis:

Regarding employment relations: Article 9(a) and (b) of the Conditions of Employment for Staff of the ECB; Article 2.0 (conversion of contracts for a definite period) of the ECB Staff Rules read in conjunction with Article 10(c) of the Conditions of Employment for Staff of the ECB; Article 2.0a (conditions for non-convertible fixed-term contracts and successive contracts) of the ECB Staff Rules read in conjunction with Article 10(d) of the Conditions of Employment for Staff of the ECB; Article 2.2 (termination of contract) of the ECB Staff Rules read in conjunction with Article 11 of the Conditions of Employment for Staff of the ECB
Regarding compensation data: Article 3.1.4 of the ECB Staff Rules read in conjunction with Article 12 of the Conditions of Employment for Staff of the ECB
Regarding compensatory leave for overtime: Article 5.3.4(c) of the ECB Staff Rules read in conjunction with Article 26(a) of the Conditions of Employment for Staff of the ECB; Article 5.2.4(c) of the ECB Rules for Short-term Employment read in conjunction with Article 24(b) of the Conditions of Short-Term Employment for Staff of the ECB
Regarding long-term sick leave (i.e. sick leave uninterrupted for more than six weeks): Article 5.13.2 (sick leave) of the ECB Staff Rules read in conjunction with Article 31 of the Conditions of Employment for Staff of the ECB. While only administrative sick leave data (i.e. start and end date) are collected, categories of data concerning the health of staff may be considered to be special categories of data and may be processed in accordance with Article 10(2), point (b), of the EUDPR
Regarding disability allowance: Article 6.1 (payment during sick leave and decision to grant a disability allowance) of the ECB Staff Rules read in conjunction with Article 32(a) to (c) of the Conditions of Employment for Staff of the ECB. While only the start and end date of the entitlement to disability allowance and the allowance itself are collected, categories of data concerning the health or disability of staff may be considered to be special categories of data and may be processed in accordance with Article 10(2), point (b), of the EUDPR
Article 3.5 (household allowance) of the ECB Staff Rules read in conjunction with Article 15 of the Conditions of Employment for Staff of the ECB
Article 3.6 (child allowance) of the ECB Staff Rules read in conjunction with Article 16 of the Conditions of Employment for Staff of the ECB. Categories of data concerning the health of children of staff may be considered to be special categories of data and may be processed in accordance with Article 10(2), point (b), of the EUDPR
Article 3.7 (expatriation allowance) of the ECB Staff Rules read in conjunction with Articles 17 and 18 of the Conditions of Employment for Staff of the ECB
Article 3.8 (education allowance) of the ECB Staff Rules read in conjunction with Article 19 of the Conditions of Employment for Staff of the ECB
Article 3.8bis (pre-school allowance) of the ECB Staff Rules read in conjunction with Article 19bis of the Conditions of Employment for Staff of the ECB
Article 4.3 (travel expenses) of the ECB Staff Rules read in conjunction with Articles 22(i) and 23(i) of the Conditions of Employment for Staff of the ECB
Article 4.5 (subsistence allowance) of the ECB Staff Rules read in conjunction with Article 22(ii) of the Conditions of Employment for Staff of the ECB
Article 4.6 (installation allowance) of the ECB Staff Rules read in conjunction with Article 22(iii) of the Conditions of Employment for Staff of the ECB
Article 4.7 (resettlement allowance) of the ECB Staff Rules read in conjunction with Article 23(ii) of the Conditions of Employment for Staff of the ECB
Article 6.1 (payment during sick leave and decision to grant a disability allowance) of the ECB Staff Rules read in conjunction with Article 32(a) to (c) of the Conditions of Employment for Staff of the ECB
Article 6.2a (long-term care insurance) of the ECB Staff Rules read in conjunction with Article 33a of the Conditions of Employment for Staff of the ECB
Article 6.5 (unemployment benefits) of the ECB Staff Rules read in conjunction with Article 36 of the Conditions of Employment for Staff of the ECB
Articles 2 and 5 of Annex I (salary structure) of the Conditions of Employment for Staff of the ECB
Annex III (retirement plan) of the Conditions of Employment for Staff of the ECB
Annex IIIb (retirement scheme) of the Conditions of Employment for Staff of the ECB
Articles 2, 5, 6 and 7 of Annex IV (disability benefits) of the Conditions of Employment for Staff of the ECB
Article 1a.2 of the ECB Rules on Short-term Employment
Article 4.2 (temporary accommodation) of the ECB Rules on Short-term Employment read in conjunction with Article 21(b) of the Conditions for Short-term Employment for Staff of the ECB
Article 18 of the Conditions of Short-term Employment for Staff of the ECB

We consider that the requirements set out in Article 6 of the EUDPR are met and that the further processing is compatible with the original purpose, taking into account the following:

While the data on compensation and benefits have been collected for the purpose of ensuring the contractual rights of staff, the production of dashboards and reports, and analyses and insights regarding compensation and benefits amounts to processing for another purpose which is compatible with the original one. Ensuring that HR policies related to compensation and benefits are up to date (purpose (ii)) and reporting on workforce costs (purpose (iii)) are linked with the initial purpose for which the data has been collected. The data has been collected and further processed in the context of employment and the relationship between the data subject and controller has not changed. The processing may include special categories of data related to the health of children of staff and is processed in accordance with Article 10(2), point (b), of the EUDPR. As the statistics are used to analyse and adapt HR policies and services (purpose (ii)) and to report on workforce costs (purpose (iii)), there are no direct consequences of the further processing for data subjects. Due process would be followed in respect of any change in HR policies and services, including specific safeguards for the rights of individuals (including but not limited to consultations with staff representatives and the DPO as needed). Finally, the data is aggregated at institutional level and does not allow to identify individuals or to draw conclusions about the private lives of individuals.

14. Reports related to ECB insurances (health, long-term care, accident)

Specific legal basis:

Regarding employment relations: Article 9(a) and (b) of the Conditions of Employment for Staff of the ECB; Article 2.0 (conversion of contracts for a definite period) of the ECB Staff Rules read in conjunction with Article 10(c) of the Conditions of Employment for Staff of the ECB; Article 2.0a (conditions for non-convertible fixed-term contracts and successive contracts) of the ECB Staff Rules read in conjunction with Article 10(d) of the Conditions of Employment for Staff of the ECB; Article 2.2 (termination of contract) of the ECB Staff Rules read in conjunction with Article 11 of the Conditions of Employment for Staff of the ECB
Regarding compensation data: Article 3.1.4 of the ECB Staff Rules read in conjunction with Article 12 of the Conditions of Employment for Staff of the ECB
Article 3 (conditions of insurance cover for spouses or recognised partners and former spouses or former recognised partners) of Annex III to the ECB Staff Rules read in conjunction with Article 6.2 (ECB health insurance) of the ECB Staff Rules and Article 33 of the Conditions of Employment for Staff of the ECB
Article 4 (conditions of insurance cover for children) of Annex III to the ECB Staff Rules read in conjunction with Article 6.2 (ECB health insurance) of the ECB Staff Rules and Article 33 of the Conditions of Employment for Staff of the ECB
Article 5 (conditions of insurance cover for spouses or recognised partners) of Annex IV to the ECB Staff Rules read in conjunction with Article 6.2a (ECB long-term care insurance) of the ECB Staff Rules and Article 33a of the Conditions of Employment for Staff of the ECB
Article 6 (conditions of insurance cover for children) of Annex IV to the ECB Staff Rules read in conjunction with Article 6.2a (ECB long-term care insurance) of the ECB Staff Rules and Article 33a of the Conditions of Employment for Staff of the ECB
Article 6.3 (accidents, accidents at work and occupational diseases) of the ECB Staff Rules read in conjunction with Article 34(a) and (b) of the Conditions of Employment for Staff of the ECB

15. Dashboards and reports related to relatives and associates

Specific legal basis:

Article 3.6 (child allowance) of the ECB Staff Rules read in conjunction with Article 16 of the Conditions of Employment for Staff of the ECB
Article 3.8 (education allowance) of the ECB Staff Rules read in conjunction with Article 19 of the Conditions of Employment for Staff of the ECB
Article 3.8bis (pre-school allowance) of the ECB Staff Rules read in conjunction with Article 19bis of the Conditions of Employment for Staff of the ECB

We consider that the requirements set out in Article 6 of the EUDPR are met and that the further processing is compatible with the initial one for which the data has been collected, taking into account the following:

While the data regarding children has been collected for the purpose of ensuring the contractual rights of staff, the production of aggregated statistics regarding children of staff and their age groups amounts to processing for another purpose which is compatible with the original one. Ensuring that HR can offer sufficient capacity for services such as child minding and schooling is linked with the initial purpose for which the data has been collected. The data has been collected and further processed in the context of employment and the relationship between the data subject and controller is unchanged. As the statistics are used to adapt HR policies and services, there are no direct consequences of the further processing for data subjects. Due process would be followed in respect of any change in HR policies and services, including specific safeguards for the rights of individuals (including but not limited to consultations with staff representatives, the DPO and the EDPS as needed). Finally, the data is pseudonymised in the data preparation step and the statistics are provided at institutional level.

16. ASBR calibration tool

Specific legal basis:

Regarding employment relations: Article 9(a) and (b) of the Conditions of Employment for Staff of the ECB; Article 2.0 (conversion of contracts for a definite period) of the ECB Staff Rules read in conjunction with Article 10(c) of the Conditions of Employment for Staff of the ECB; Article 2.0a (conditions for non-convertible fixed-term contracts and successive contracts) of the ECB Staff Rules read in conjunction with Article 10(d) of the Conditions of Employment for Staff of the ECB
Regarding the ASBR: Article 5 of Annex I (salary structure) of the Conditions of Employment for Staff of the ECB and the Annual Salary & Bonus Review (ASBR) Guidelines as adopted by the Executive Board (SEC/EB/20/1171/14a)
Regarding part-time work: Articles 5.2.1 and 5.2.2 of the ECB Staff Rules read in conjunction with Article 25 of the Conditions of Employment for Staff of the ECB
Regarding maternity measures for the ASBR: point 3 of the implementing rules and frequently asked questions on ASBR as adopted by the Executive Board (SEC/EB/20/1171/14b)
Article 2a.8 (promotion: definition and general provisions) of the ECB Staff Rules read in conjunction with Article 11a of the Conditions of Employment for Staff of the ECB
Article 2a.10 (promotion to the next salary bracket of current position) of the ECB Staff Rules read in conjunction with Article 11a of the Conditions of Employment for Staff of the ECB
Article 2a.11 (promotion to the next salary band of current position) of the ECB Staff Rules read in conjunction with Article 11a of the Conditions of Employment for Staff of the ECB

17. Dashboards and reports related to salary progression and bonuses

Specific legal basis:

Regarding employment relations: Article 9(a) and (b) of the Conditions of Employment for Staff of the ECB; Article 2.0 (conversion of contracts for a definite period) of the ECB Staff Rules read in conjunction with Article 10(c) of the Conditions of Employment for Staff of the ECB; Article 2.0a (conditions for non-convertible fixed-term contracts and successive contracts) of the ECB Staff Rules read in conjunction with Article 10(d) of the Conditions of Employment for Staff of the ECB;
Regarding part-time work: Articles 5.2.1 and 5.2.2 of the ECB Staff Rules read in conjunction with Article 25 of the Conditions of Employment for Staff of the ECB
Regarding the ASBR: Article 5 of Annex I (salary structure) of the Conditions of Employment for Staff of the ECB and the Annual Salary & Bonus Review (ASBR) Guidelines as adopted by the Executive Board (SEC/EB/20/1171/14a)
Regarding the publication of statistics regarding ASBR: point 8 of the implementing rules and frequently asked questions on ASBR as adopted by the Executive Board (SEC/EB/20/1171/14b)
Regarding compensation data: Article 3.1.4 of the ECB Staff Rules read in conjunction with Article 12 of the Conditions of Employment for Staff of the ECB
Article 2a.8 (promotion: definition and general provisions) of the ECB Staff Rules read in conjunction with Article 11a of the Conditions of Employment for Staff of the ECB
Article 2a.10 (promotion to the next salary bracket of current position) of the ECB Staff Rules read in conjunction with Article 11a of the Conditions of Employment for Staff of the ECB
Article 2a.11 (promotion to the next salary band of current position) of the ECB Staff Rules read in conjunction with Article 11a of the Conditions of Employment for Staff of the ECB

We consider that the requirements set out in Article 6 of the EUDPR are met and that the processing is compatible with the purpose for which the data has been initially collected, taking into account, inter alia, the following:

While the data has been collected for the purpose of managing the rights and obligations of staff, the processing by HR Analytics amounts to processing for another purpose which is compatible with the original one. Ensuring fairness and transparency (purpose (i)), that ASBR policies are effective and up to date (purpose (ii)) and checking eligibility for promotion (purpose (iii)) are linked with the initial purpose for which the data has been collected. The data has been collected and further processed in the context of employment and the relationship between the data subject and controller has not changed. There are no direct consequences of the further processing for data subjects. Due process would be followed in respect of the taking of any act affecting staff, including specific safeguards for the rights of individuals (such as consultations with staff representatives). Finally, for purposes (i) and (ii), the statistics are aggregated at institutional and business area level to the extent that individuals cannot be identified and no conclusions can be drawn about the private lives of individuals.

18. Analyses and insights related to salary progression and bonuses

Specific legal basis:

Regarding employment relations: Article 9(a) and (b) of the Conditions of Employment for Staff of the ECB; Article 2.0 (conversion of contracts for a definite period) of the ECB Staff Rules read in conjunction with Article 10(c) of the Conditions of Employment for Staff of the ECB; Article 2.0a (conditions for non-convertible fixed-term contracts and successive contracts) of the ECB Staff Rules read in conjunction with Article 10(d) of the Conditions of Employment for Staff of the ECB
Regarding part-time work: Articles 5.2.1 and 5.2.2 of the ECB Staff Rules read in conjunction with Article 25 of the Conditions of Employment for Staff of the ECB
Regarding the ASBR: Article 5 of Annex I (salary structure) of the Conditions of Employment for Staff of the ECB and the Annual Salary & Bonus Review (ASBR) Guidelines as adopted by the Executive Board (SEC/EB/20/1171/14a)
Regarding compensation data: Article 3.1.4 of the ECB Staff Rules read in conjunction with Article 12 of the Conditions of Employment for Staff of the ECB
Regarding age: Article 38 (pension) of the Conditions of Employment for Staff of the ECB
Regarding gender: Article 5.9 (maternity and adoptive leave) of the ECB Staff Rules read in conjunction with Article 28(i) and (ii) of the Conditions of Employment for Staff of the ECB; Article 5.8 (maternity and adoptive leave) of the ECB Rules for Short-Term Employment read in conjunction with Article 27(i) and (ii) of the Conditions of Short-Term Employment for Staff of the ECB
Regarding nationality: Articles 17 and 18 of the Conditions of Employment for Staff of the ECB
Regarding teleworking: Article 5.1bis.4 (quota and place of teleworking) of the ECB Staff Rules read in conjunction with Article 25 of the Conditions of Employment for Staff of the ECB; Article 5.1bis (teleworking) of the ECB Rules for Short-term Employment read in conjunction with Article 23(b) of the Conditions of Short-Term Employment for Staff of the ECB; Article 9a(6) of Decision ECB/2015/NP13 (rules governing the traineeship programme of the ECB)
Regarding unpaid parental leave: Article 5.11.1 of the ECB Staff Rules read in conjunction with Article 29 of the Conditions of Employment for Staff of the ECB
Regarding unpaid leave: Articles 5.12.1, 5.12.1a and 5.12.1b of the ECB Staff Rules read in conjunction with Article 30 of the Conditions of Employment for Staff of the ECB
Regarding long-term sick leave (i.e. sick leave uninterrupted for more than six weeks): Article 5.13.2 (sick leave) of the ECB Staff Rules read in conjunction with Article 31 of the Conditions of Employment for Staff of the ECB; Article 5.10.2 (sick leave) of the ECB Staff Rules read in conjunction with Article 28 of the Conditions of Employment for Staff of the ECB; Article 9(3) (attendances and absences) of Decision ECB/2015/NP13 (rules governing the traineeship programme of the ECB)

We consider that the requirements set out in Article 6 of the EUDPR are met and that the processing is compatible with the purpose for which the data has been initially collected, taking into account, inter alia, the following:

While the data has been collected for the purpose of managing the compensation and benefits of staff, the production of aggregated statistics regarding ASBR amounts to processing for another purpose which is compatible with the original one. Ensuring that the ASBR policy is effective and up to date is linked with the initial purpose for which the data has been collected. The data has been collected and further processed in the context of employment and the relationship between the data subject and controller has not changed. In the interim stage, categories of data which may be considered as special categories, i.e. administrative data about long-term sick leave (limited to start and end date of that type of absence), are processed. This is necessary to check for biases. The data is limited to what is necessary, i.e. the start and end date of long-term sick leave. While administrative data regarding long-term sick leave may be considered to be a special category concerning health, it is processed in accordance with Article 10(2), point (b), of the EUDPR. As the statistics are used to analyse the effectiveness of the ASBR policy, there are no direct consequences of the further processing for data subjects. Due process would be followed in respect of the making of any change in the ASBR policy, including specific safeguards for the rights of individuals (such as consultations with staff representatives). Finally, the statistics are aggregated to the extent that they are anonymised, at institutional and business area level.

19. Dashboard and reports as well as analyses and insights related to promotions and transfers

Specific legal basis:

Regarding mobility: Article 2a.7 (mobility) of the ECB Staff Rules read in conjunction with Article 8a(b), subparagraph (ii), of the Conditions of Employment for Staff of the ECB
Regarding promotions without recruitment: Articles 2a.10 (promotion to the next salary bracket of current position), 2a.11 (promotion to the next salary band of current position), 2a.12 (promotion to a higher salary band for a period of less than one year) and 2a.14 (effects of promotion) of the ECB Staff Rules read in conjunction with Article 8a(b), subparagraph (iii), of the Conditions of Employment for Staff of the ECB
Regarding promotions with recruitment: Articles 1a.3.2 and 1a.3.3 of the ECB Staff Rules read in conjunction with Article 8a(b), subparagraph (iii), of the Conditions of Employment for Staff of the ECB
Regarding direct appointments: Articles 1a.3.6 and 1a.3.7 of the ECB Staff Rules read in conjunction with Article 8a(b), subparagraph (iv), of the Conditions of Employment for Staff of the ECB
Regarding the ASBR: Article 5 of Annex I (salary structure) of the Conditions of Employment for Staff of the ECB and the Annual Salary & Bonus Review (ASBR) Guidelines as adopted by the Executive Board (SEC/EB/20/1171/14a)
Regarding parenthood: Article 3.6 (child allowance) of the ECB Staff Rules read in conjunction with Article 16 of the Conditions of Employment for Staff of the ECB, Article 5.10.1, subparagraphs (c) and (cc), of the ECB Staff Rules read in conjunction with Article 28(iii) of the Conditions of Employment for Staff of the ECB

We consider that the requirements set out in Article 6 of the EUDPR are met, taking into account the following:

While the data about mobility and promotions have been collected for the purpose of enabling the mobility and promotions of staff, the processing by HR Analytics amounts to processing for another purpose which is compatible with the original one. Managing talent and succession planning (purpose (i)) and ensuring that policies and HR services related to mobility and promotions are up to date (purpose (ii)) are linked with the initial purpose for which the data has been collected. The data has been collected and further processed in the context of employment and the relationship between the data subject and controller is unchanged. There are no direct consequences of the further processing for data subjects. Any decision or change in HR policies and services would follow due process, including specific safeguards for the rights of individuals (such as consultations with staff representatives and the DPO). Finally, for purpose (ii), the statistics are aggregated at institutional and business area level to the extent that no individuals can be identified and no conclusions can be drawn about the private lives of individuals.

Similarly, data about parenthood have been collected for the purpose of carrying out the specific rights of data subjects (i.e. child allowance and special leave in the event of birth or adoption) and is being processed here to check for indirect discrimination against parents with regard to promotions and transfers. This purpose is compatible with the original one. The data on parenthood has been collected and further processed in the context of employment and the relationship between the data subject and controller is unchanged. As the statistics are used to analyse and adapt HR policies and services, there are no direct consequences of the further processing for data subjects. Due process would be followed in respect of the making of any change in HR policies, including specific safeguards for the rights of individuals (such as consultations with staff representatives and the DPO). Finally, the statistics are aggregated at institutional and business area level to the extent that no individuals can be identified and no conclusions can be drawn about the private lives of individuals.

20. Dashboards and reports related to trainings

Specific legal basis:

Regarding professional development: Article 2a.3 (interim review) and 2a.4 (annual review) of the ECB Staff Rules read in conjunction with Article 11a of the Conditions of Employment for Staff of the ECB
Regarding trainings related to ethics framework: Part 0 (ethics framework) of the Staff Rules read in conjunction with Article 3 of the Conditions of Employment for Staff of the ECB; Part 0 (ethics framework) of the Staff Rules read in conjunction with Article 2 of the Conditions of Short-Term Employment for Staff of the ECB; Article 11(1), point (a), of Decision ECB/2015/NP13 (rules governing the traineeship programme of the ECB)
Regarding trainings related to DARWIN and other ECB-specific tools: Article 2(b) of the Conditions of Short-Term Employment for Staff of the ECB; Article 11(1), point (c), of Decision ECB/2015/NP13 (rules governing the traineeship programme of the ECB)
Regarding age: Article 38 (pension) of the Conditions of Employment for Staff of the ECB
Regarding gender: Article 5.9 (maternity and adoptive leave) of the ECB Staff Rules read in conjunction with Article 28(i) and (ii) of the Conditions of Employment for Staff of the ECB; Article 5.8 (maternity and adoptive leave) of the ECB Rules for Short-Term Employment read in conjunction with Article 27(i) and (ii) of the Conditions of Short-Term Employment for Staff of the ECB
Regarding nationality: Articles 17 and 18 of the Conditions of Employment for Staff of the ECB
Regarding EU nationality as a precondition for appointment: Article 8a(a), subparagraph (i), of the Conditions of Employment for Staff of the ECB; Article 4(1), point (c), of Decision ECB/2015/NP13 (rules governing the traineeship programme of the ECB)

We consider the requirements of Article 6 of the EUDPR are met, taking into account the following: While the data about trainings, age, gender and nationality have been collected for the purpose of giving effect to the contractual rights and obligations of staff, the processing by HR Analytics, including demographics (i.e. age, gender, nationality), amounts to processing for another purpose which is compatible with the original one. Developing talent (purpose (i)) and advising managers on how to go about it (purpose (ii)), as well as ensuring that policies and HR services related to professional development are up to date (purpose (iii)) are linked with the initial purpose for which the data has been collected. The data has been collected and further processed in the context of employment and the relationship between the data subject and controller has not changed. There are no direct consequences of the further processing for data subjects. Any act affecting staff or actual change in HR policies and services would follow due process, including specific safeguards for the rights of individuals (such as consultations with staff representatives, the DPO). Finally, for purpose (ii), the statistics are aggregated at divisional, business area and institutional level to the extent that no individuals can be identified and no conclusions can be drawn about the private lives of individuals.

21. Dashboards and reports related to sourcing, recruitment campaigns, and mobility opportunities

Specific legal basis:

Regarding recruitment: Article 1a (selection and appointment) of the Staff Rules read in conjunction with Article 8a(b), subparagraph (i), of the Conditions of Employment for Staff of the ECB
Regarding mobility: Article 2a.7 (mobility) of the Staff Rules read in conjunction with Article 8a(b), subparagraph (ii), of the Conditions of Employment for Staff of the ECB
Regarding appointments from the reserve list: Article 1a.3.3 of the Staff Rules read in conjunction with Article 8a(b), subparagraph (i), of the Conditions of Employment for Staff of the ECB
Regarding employment relations: Article 9(a) and (b) of the Conditions of Employment for Staff of the ECB; Article 2.0 (conversion of contracts for a definite period) of the ECB Staff Rules read in conjunction with Article 10(c) of the Conditions of Employment for Staff of the ECB; Article 2.0a (conditions for non-convertible fixed-term contracts and successive contracts) of the ECB Staff Rules read in conjunction with Article 10(d) of the Conditions of Employment for Staff of the ECB
Regarding age: Article 38 (pension) of the Conditions of Employment for Staff of the ECB
Regarding gender in recruitment: Article 1a.2.1.1 of the ECB Staff Rules read in conjunction with Article 8a of the Conditions of Employment for Staff of the ECB
Regarding EU nationality as precondition for appointment: Article 8a(a), subparagraph (i), of the Conditions of Employment for Staff of the ECB; Article 4(1), point (c), of Decision ECB/2015/NP13 (rules governing the traineeship programme of the ECB)

We consider the requirements of Article 6 of the EUDPR are met and therefore the processing to be compatible with the purpose for which the personal data were initially collected, taking into account the following: While the data about recruitment and mobility have been collected for the purpose of carrying out the specific obligations of the ECB, the processing by HR Analytics, including the demographics (i.e. age, gender, nationality), amounts to processing for another purpose which is compatible with the original one. Supporting sourcing (purpose (i)), ensuring that the recruitment and mobility processes are managed effectively (purpose (ii)) and that the policies related to recruitment and mobility are up to date (purpose (iii)) are linked with the initial purpose for which the data has been collected. The data has been collected and further processed in the context of employment and the relationship between the data subject and controller has not changed. There are no direct consequences of the further processing for data subjects. Any act affecting staff or any actual change in HR policies would follow due process, including specific safeguards for the rights of individuals (such as consultations with staff representatives, the DPO). Finally, for purposes (ii) and (iii), the statistics are aggregated at institutional and business area level to the extent that no individuals can be identified and no conclusions can be drawn about the private lives of individuals.

22. Analyses and insights related to sourcing, recruitment campaigns and mobility opportunities

Specific legal basis:

Regarding recruitment (including promotion via recruitment): Articles 1a.3.2 and 1a.3.3 of the Staff Rules read in conjunction with Article 8a(b), subparagraph (i), of the Conditions of Employment for Staff of the ECB
Regarding mobility: Article 2a.7 (mobility) of the Staff Rules read in conjunction with Article 8a(b), subparagraph (ii), of the Conditions of Employment for Staff of the ECB
Article 2a.10 (promotion to the next salary bracket of current position) of the ECB Staff Rules read in conjunction with Article 11a of the Conditions of Employment for Staff of the ECB
Article 2a.11 (promotion to the next salary band of current position) of the ECB Staff Rules read in conjunction with Article 11a of the Conditions of Employment for Staff of the ECB
Regarding employment relations: Article 9(a) and (b) of the Conditions of Employment for Staff of the ECB; Article 2.0 (conversion of contracts for a definite period) of the ECB Staff Rules read in conjunction with Article 10(c) of the Conditions of Employment for Staff of the ECB; Article 2.0a (conditions for non-convertible fixed-term contracts and successive contracts) of the ECB Staff Rules read in conjunction with Article 10(d) of the Conditions of Employment for Staff of the ECB
Regarding the ASBR: Article 5 of Annex I (salary structure) of the Conditions of Employment for Staff of the ECB and the Annual Salary & Bonus Review (ASBR) Guidelines as adopted by the Executive Board (SEC/EB/20/1171/14a)
Regarding compensation data: Article 3.1.4 of the ECB Staff Rules read in conjunction with Article 12 of the Conditions of Employment for Staff of the ECB
Regarding age: Article 38 (pension) of the Conditions of Employment for Staff of the ECB
Regarding gender in recruitment: Article 1a.2.1.1 of the ECB Staff Rules read in conjunction with Article 8a of the Conditions of Employment for Staff of the ECB
Regarding EU nationality as a precondition for appointment: Article 8a(a), subparagraph (i), of the Conditions of Employment for Staff of the ECB; Article 4(1), point (c), of Decision ECB/2015/NP13 (rules governing the traineeship programme of the ECB)

We consider the requirements of Article 6 of the EUDPR are met and therefore the processing to be compatible with the purpose for which the personal data were initially collected, taking into account the following: While the data on sourcing, recruitment and mobility have been collected for the purpose of carrying out the specific obligations of the ECB, the processing of HR Analytics, including with regard to demographics (i.e. age, gender, nationality), amounts to processing for another purpose which is compatible with the original one. Ensuring that the sourcing, recruitment, and mobility processes are managed effectively and that the related policies are up to date are linked with the initial purpose for which the data has been collected. The data has been collected and further processed in the context of employment and the relationship between the data subject and controller has not changed. As the statistics are used to analyse and adapt HR policies, there are no direct consequences of the further processing for data subjects. Due process would be followed in respect of the making of any change in HR policies, including specific safeguards for the rights of individuals (such as consultations with staff representatives and the DPO). Finally, the statistics are aggregated at institutional and business area level to the extent that no individuals can be identified, and no conclusions can be drawn about the private lives of individuals.

23. Reports for the financial compliance check (DG-SE/CGO)

Specific legal basis:

Article 0.4.3 (compliance monitoring) of the Staff Rules read in conjunction with Article 3 of the Conditions of Employment for Staff of the ECB; Article 2 of the Conditions of Short-Term Employment for Staff of the ECB; Article 11(1), point (a), of Decision ECB/2015/NP13 (rules governing the traineeship programme of the ECB)

Who is responsible for processing your personal data?

The ECB is the controller for the processing of your personal data. The Employee Services Division is responsible for this processing.

Who will be the recipients of your personal data?

The recipients of your personal data (including entities who have access to that personal data) may be:

Data subjects themselves
Designated HR personnel (non-HR Analytics)
Line managers, direct supervisors and management teams of relevant data subjects
Management assistants (with management approval)
Designated staff in the relevant reporting line with a business need to process the data
Designated third-party business area representatives with a business need to process the data
ECB employees
ECB-external parties (such as national governments)

Access to the processed data is restricted on a need to know basis. The access to processed personal data is guided by the existing access principles (e.g. rationale behind ISIS authorisation).

In the event of requests from external parties, such as (European) National Central Banks (NCB)/National Competent Authorities (NCA), International Financial Institutions, European institutions, bodies or agencies, or EU national public organisations, only aggregated data are shared, unless required by the applicable legislation.

What categories of personal data are collected?

The ECB processes the following personal data:

Personal information data:
- Subcategories of data: staff ID, name, surname, gender^[3], date of birth / age, nationality/nationalities, contact information
- Data subjects: ECB staff (including graduates), short-term staff (including ESCB/IOs) and trainees, pensioners, internal and external applicants
- Source system: SAP
Position and employment data:
- Subcategories of data: organisational assignment (i.e. position assignment, organisational unit assignment), contract information (i.e. contract type, e.g. fixed-term, start and end date of the contract), working time^[4]
- Data subjects: ECB staff (including graduates), short-term staff (including ESCB/IOs) and trainees, ECB external contract holders
- Source system: SAP
Compensation data:
- Subcategories of data (where applicable): salary band, salary band level (i.e. level in band), allowances, ASBR
- Data subjects: ECB staff (including graduates), short-term staff (including ESCB/IOs) and trainees, pensioners
- Source system: SAP
Attendance and absence data^[5]:
- Subcategories of data: attendance information (i.e. teleworking, overtime, business trip), absence information (i.e. annual leave, recuperation days, compensatory leave, administrative sick leave data^[6], maternity leave, unpaid leave, different kinds of special leave, etc.)
- Data subjects: ECB staff (including graduates), short-term staff (including ESCB/IOs) and trainees
- Source system: SAP
Education and training data:
- Subcategories of data: course information/ training activities information, training / activity participation
- Data subjects: ECB staff (including graduates), short-term staff (including ESCB/IOs) and trainees, NCB and NCA staff
- Source system: EUREKA (im-c)
Career data:
- Subcategories of data: mobility, promotions, skills and experience, role profiles (and role specialisations); only for SSM staff in the rotation exercise preferences for Joint Supervisory Teams (JSTs)
- Data subjects: ECB staff (including graduates)
- Source system: SAP, Avature
Recruitment data:
- Subcategories of data: campaign ID and information*, applicant and application information^[7]
- Data subjects: internal and external applicants
- Source system: Avature
Family and social circumstances data:
- Subcategories of data (where applicable): parenthood, marital status, names of dependents
- Data subjects: ECB staff (including graduates), short-term staff (including ESCB/IOs), relatives and associates of the data subjects
- Source system: SAP
Pensions data:
- Subcategories of data: membership of the Pension Plan or Scheme, allowances
- Data subjects: ECB staff (including graduates), pensioners
- Source system: SAP

Sources: personal data have been input by the data subjects, generated by the system, or entered by the data subjects’ management or by HR personnel in the relevant system, in ISIS (the ECB’s SAP implementation as the main HR information system), Avature (for talent management and recruitment), or EUREKA (the ECB training system).

It should be noted that processing in most, if not all, cases involve processing one or some of the data categories listed above and does not integrate all data categories.

Special categories of personal data can be categorised into the four following data types, which may be processed through one or more of the processing activities:

Absences data: administrative sick leave data^[8]; this refers to data subjects who are on sick leave, i.e. a subset of “ECB staff including graduates, short-term staff including ESCB/IOs, and trainees”, amounting to approximately 2,500 to 3,300 data subjects yearly.
Family and social circumstances data: gender of spouse or recognised partner which may allow an inference to be made concerning sexual orientation; this refers to data subjects who have a spouse or recognised partner registered, i.e. a subset of “ECB staff including graduates, short-term staff including ESCB/IOs, and trainees” and of “pensioners”, amounting to approximately 2,750 data subjects overall.
Compensation data: double child allowance which allows an inference to be made concerning children with special needs or disability; this refers only to data subjects who receive a double child allowance, i.e. a subset of “ECB staff including graduates, short-term staff including ESCB/IOs, and trainees” and of “pensioners”, amounting to approximately 50 data subjects overall.
Position and employment data: allocation to a specific organisational unit could allow an inference to be made concerning someone’s sick leave or disability status; this refers only to data subjects who are on long-term sick leave or on full or partial disability, i.e. a subset of “ECB staff including graduates, short-term staff including ESCB/IOs, and trainees”, amounting to approximately 250 to 300 data subjects.

Will your personal data (in a clear or encrypted form) be processed (i.e. transferred, accessed or stored) in third countries or by international organisations?

Your personal data might exceptionally be processed in third countries/international organisations based on the derogations for specific situations set out in Article 50(1) of the EUDPR.

Your personal data will also be processed in third countries or by international organisations based on appropriate safeguards (pursuant to Article 48 of the EUDPR). These are provided by Standard Contractual Clauses (SCCs).

If the third country’s legislation and/or practices have an impact on the effectiveness of these appropriate safeguards, your personal data can only be transferred to, accessed from or processed in that third country where sufficient supplementary measures are taken to ensure an essentially equivalent level of protection to that guaranteed within the European Economic Area (EEA). These supplementary measures are implemented on a case-by-case basis and may be technical (such as encryption), organisational and/or contractual.

You can request a copy of the appropriate or suitable safeguards from the ECB’s Data Protection Officer.

How long will the ECB keep personal data?

Your personal data will be stored in compliance with the ECB retention plan in the source systems and in the analytical system (DISC/DEVO Corporate Stores in an AWS cloud) where they are synchronised. The retention period depends on the personal data processed. Data may also be stored in DISC/DEVO Data Labs (including in an AWS cloud), DARWIN, on the Tableau server, or temporarily locally.

In addition to the ECB retention plan, it should be clarified that, for many processing activities, the data period being processed is shorter. You can find the used data history per processing activity below, specified by purpose.

Use case	Purpose	Data history
Dashboards and reports related to leave	Providing personal data about annual leave schedule, consumption, and entitlement to line managers (and where requested management assistants), supervisors and management teams of data subjects for ensuring compliance with contractual and legal duties according to the Conditions of Employment for Staff of the ECB and the ECB Staff Rules, for managing staff wellbeing as well as for resource planning and management (purpose A.1) Providing personal data about annual leave schedule, consumption, and entitlement of data subjects to designated HR personnel who use the information for consulting and supporting managers (purpose A.1) Providing annual leave statistics and/or statistics of other leave types (non-personal data) to designated HR personnel^[9] for assessing the appropriateness of the policies and HR services related to wellbeing, absences and attendances and identifying ways to improve these (purpose A.2)	Data for purposes (i) and (ii) are provided to data recipients for the current year and the previous calendar year. Purpose (iii), without personal data in the end product, may include a history of up to five years to derive trends and draw more robust conclusions for HR solutions.
Analyses and insights related to leave (excluding sick leave)	Providing aggregated statistics (non-personal data) and insights to designated HR personnel for assessing the appropriateness of the policies and HR services related to wellbeing, absences, leave, and attendances and identifying ways to improve these (purpose A.2)	The output data / end product (without personal data) may include a history of up to five years to derive trends and draw more robust conclusions for HR solutions.
Dashboards and reports as well as analyses and insights related to sick leave	Providing personal data about sick leave to the line manager (or maximum two line managers) of the data subject and to designated HR personnel (usually one or two HR business partners advising the manager) supporting managers: for managing wellbeing (duty of care) and their resources, using current sick leave (purpose A.1); in very few complex situations involving sick leave for supporting reintegration at work after continuous sick leave of more than six weeks, supporting and reminding staff to provide sick leave certificates (purpose A.1) Providing sick leave statistics (non-personal data) to designated HR personnel for assessing the appropriateness of the policies and HR services related to wellbeing, absences, leave and attendances and identifying ways to improve these (purpose A.2)	Data for purpose (i)(a) are provided to data recipients for current absences justified by sickness. Data for purpose (i)(b)(i) are only provided in a few incidental cases and for a history of up to three years, for (i)(b)(ii) for up to two months. End-products without personal data for purpose (ii) may include a history of up to five years to derive trends and draw more robust conclusions for HR solutions.
Dashboards and reports as well as analyses and insights related to working time and attendances	Providing personal data about working time, overtime, recuperation days, teleworking to supervisors and managers (and where requested management assistants) of data subjects for managing staff and trainees’ wellbeing and resources (purpose A.1) Providing personal data about working time, overtime, recuperation days, teleworking of data subjects to designated HR staff for consulting and supporting managers and for checking compliance of staff and trainees with teleworking rules (purpose A.1) Providing attendance statistics (non-personal data) to designated HR personnel for assessing the appropriateness of the policies and HR services related to wellbeing, absences, leave and attendances and identifying ways to improve these (purpose A.2)	Data for purposes (i) and (ii) are provided to data recipients for one rolling year. End-products without personal data for purpose (iii) may include a history of up to five years to derive trends and draw more robust conclusions for HR solutions.
Dashboards and reports as well as analyses and insights related to positions, contracts, and employment	Providing personal data about position allocation, contracts, including leavers and new starters to line managers, supervisors, and management teams as well as to management assistants of data subjects for onboarding, for resource planning and management and for contract management (purpose A.1) Providing personal data about position allocation, contracts, including leavers and new starters to designated HR personnel (e.g. HR business partners) for advising regarding to the above (purpose A.1) Providing personal data about contracts, in specific leavers, to designated HR personnel (e.g. HR employee partners) for planning and organising farewell surveys and farewell talks (purpose A.1) Providing personal data about position allocation, contracts, including leavers and new starters to designated HR personnel (e.g. HR operations) for managing contracts and employment (purpose A.1) Providing aggregated statistics about position allocation, contracts, including leavers and new starters (non-personal data) to designated HR personnel for assessing the appropriateness of the policies and HR services related to resource planning and management, contracts and employment and identifying ways to improve these (purpose A.2)	Data for purposes (i) and (ii) are provided to data recipients for the current calendar year (including all current contracts and leave and their start date and duration) and up to two rolling years in the future. For purposes (iii) and (iv), only the current (rolling) year is considered. End-products without personal data for purpose (v) may include the full available data history to derive trends and draw more robust conclusions for HR solutions.
Dashboards and reports as well as analyses and insights related to the organisation and role profiles	Providing personal data about the assignment to organisational units, contract types and role profiles to line managers, supervisors, and management teams for identifying the availability of talent within the ECB assigned to different role profiles and role specialisations and for better resource planning and for talent development (purpose A.1) Providing statistics about organisational unit, contract types and role profiles (non-personal data) to designated HR personnel for assessing the appropriateness of the policies and HR services related to organisational design, position management and generic role profiles and identifying ways to improve these (purpose A.2)	Data for purpose (i) are provided to data recipients for the current year. End-products without personal data for purpose (ii) may include the full available history to derive trends and draw the most robust conclusions for HR solutions.
Position Plan simulation tool	Providing personal data related to the abovementioned data categories to managers (and where requested management assistants) and designated staff in the reporting line who are responsible for resource planning / position planning, in order to fulfil their duties and thereby enable business operations and business continuity (purpose A.1) Providing personal data related to the abovementioned data categories to designated HR personnel in order to support managers and business area focal point to use the tool and in order to advise them regarding resource planning (purpose A.1)	Data are provided to data recipients for the previous calendar year and up to two rolling years in the future.
Strategic Workforce Planning (SWFP) tool	Providing aggregated non-personal data on employment and the position as well as contract structure to line managers, supervisors, and management teams of data subjects for planning workforce and organisational development (purpose A.1) Providing position-related data on the number of positions that can be upgraded, considering the eligibility for promotion of the position holder (i.e. data subject), to line managers, supervisors, and management teams; this is needed for planning the workforce (banding and staffing), promotions, and succession (purpose A.1) Providing the above to designated HR personnel in order to support managers and business area focal point to use the tool and in order to advise them in the SWFP process (purpose A.1)	All personal data are shown for the current year, except for promotion and ASBR data which are shown for the last two years so that data recipients can determine eligibility for promotion without recruitment; aggregated data about positions and about the contract structure (non-personal) may be shown for up to 10 closed calendar years.
SSM rotation tool	Banking supervision has a legal obligation to rotate staff among JSTs in order to avoid the supervision of an entity by the same supervisor for multiple years. The tool suggests optimal scenarios for the allocation staff to JSTs in terms of matching staff preference and JST demand. Providing designated third-party business area representatives and staff in the reporting line who are responsible for carrying out the rotation exercise (and their management) the functionality to weight criteria for finding good allocations of staff to JSTs and get scenarios as an outcome that can be examined and modified as needed^[10]; final decisions are then taken based on human assessment and usually modifications of the proposed assignments. (purpose A.1)	Data are only used for the current state (i.e. a snapshot is taken from the databased and updated when needed); and the preference and skill data are also concurrent.
Dashboards and reports as well as analyses and insights related to demographics and diversity	Providing aggregated, personal and non-personal data and statistics about gender, and/or aggregated non-personal data about nationality to line managers, supervisors, and management teams of data subjects; data are aggregated, but may still allow for indirect identification of the data subjects by data recipients (only applies to managers of data subjects, who have access these data already, and only to data types that are available to managers already)^[11]; purpose is managing diversity and representation of gender and nationalities (purpose A.1) Providing aggregated statistics (non-personal data) about gender, age, and/or nationality to ECB employees and trainees to create transparency (purpose A.2) Providing aggregated statistics (non-personal data) about gender, age, and/or nationality to designated HR personnel for assessing the appropriateness of the policies and HR services related to diversity and inclusion, benefits, or social integration and identifying ways to improve them (purpose A.2) Providing personal data related to the demographic and diversity aspects (limited to gender and age) to line managers, supervisors, and management teams of data subjects and designated HR personnel to identify possible issues such as biases or lack of diversity in specific teams (purpose A.1) For the above, contract type, organisational unit and salary band / job title may be processed in addition to the demographic and diversity data. In addition, personal data are prepared and shared with the German government (only names, addresses and nationalities of ECB employees and trainees) to comply with the Headquarters Agreement (purpose B); requests by Member State national governments (only names, “grades” [salary band] and addresses) to comply with the Headquarters Agreement (purpose B).	Data for purposes (i), (v) and (vi) are provided to data recipients for the current year only. End-products without personal data for purposes (ii), (iii) and (iv) may include a history of up to 10 years to derive trends and draw more robust conclusions for HR solutions.
Gender pay gap analyses	Providing aggregated statistics (non-personal data) and insights to designated HR personnel for assessing the appropriateness of the policies and HR services and identifying ways to improve them (purpose A.2) Performing gender pay gap analyses and sharing the results (non-personal data) with auditors from Economic Dividends for Gender Equality (EDGE) to become certified as an employer with regard to gender equality (purpose A.1)	Payment data are only used for the year for which the pay gap analysis is conducted (typically for the last year and the year before, as the analysis has been run every two years); the same applies for organisational assignments. Contract information and the salary band are used for the full employment history, as the salary gap is controlled for a difference in tenure and tenure by salary band.
Projections of the demographical development of the ECB	Providing aggregated statistics/projections (non-personal data) and insights about the future development of: the workforce age for managing succession planning and adapting the benefits, HR services and possibly administration services; the gender shares for designing and improving the gender strategy; the distribution of staff across bands to evaluate, guide and improve promotion as well as upgrade and downgrade policies; the salary mass for taking strategic and operational decision on budgeting and for advising the budget-related governance bodies. Results are provided to designated personnel (and managers) in DG-HR and DG-CS (who are also involved in managing resources and budget as per their role in the organisation) (purpose A.2).	Personal information as model input in step 2 are taken only for the current year and are pseudonymised. The data for the assumptions are taken for five years for promotion rates, mobility, contract information (including resignations and retirements), and for one year for recruitment-based data.
Dashboards and reports as well as analyses and Insights related to compensation and benefits	Providing personal data about benefits, allowances and the data related to the eligibility criteria to designated HR personnel for validating eligibility for allowances and for performing spot checks (i.e. reviewing necessary certificates and documentation for allowances) for the same purpose (purpose A.1) Providing aggregated statistics (non-personal data) to designated HR personnel for assessing the appropriateness of the policies and HR services related to compensation and benefits and identifying ways to improve them (purpose A.2) Providing aggregated statistics (non-personal data) to report workforce costs and different cost elements to designated personnel (and managers) in DG-HR and D-F in line with the ECB’s budgetary processes (purpose A.1 and A.2)	Only the current year for purpose (i), and the full available history for purposes (ii) and (iii).
Reports related to ECB insurances (health, long-term care, accident)	Providing personal data about health insurance and long-term care memberships to designated HR personnel for data reconciliation (only ID, names and membership of staff member and dependants)^[12] (purpose A.1)	Only data for the past year are processed.
Dashboards and reports related to relatives and associates	Providing aggregated statistics (non-personal data) to designated HR personnel about the number and share of children across different age groups and children in the European School for managing and funding social integration services (school, crèche, family care) and ensuring the availability of these services (purpose A.1) and improve related policies (purpose A.2)	End-products do not contain personal data and may include up to five years’ data history to derive trends and draw more robust conclusions for HR solutions.
ASBR calibration tool	Providing a calibration tool containing personal data about ASBR proposals to designated HR personnel (HR business partners) who moderate calibration meetings with their client business areas and show the data during the calibration meeting^[13] Capturing adjustments of the salary increase and bonus awards in the calibration meeting, which will be transferred to ISIS thereafter The tool contains the proposals by managers initially and after the calibration meeting the steps and bonus are updated by the dedicated HR personnel, based on the discussion and alignment in the management teams and in line with the available budget. The calibration tool is needed to ensure a fair ASBR process within and across business areas and to keep costs under control while awarding salary increases and bonuses (purpose A.1).	The recent performance period (September to August) is considered for all data. For salary increases and maternity leave, five years’ history is processed as well (as the policy for promotions to the next salary band without recruitment requires such history).
Dashboards and reports related to salary progression and bonuses	Providing aggregated statistics (non-personal data) about the ASBR, considering gender, age and/or nationality, to ECB employees and trainees to provide transparency about the ASBR (purpose A.2) Providing aggregated statistics (non-personal data) to designated HR personnel for assessing the appropriateness of the policies and HR services and identifying ways to improve them (purpose A.2) Providing personal data about the ASBR from the previous year to line managers, supervisors, and management teams of data subjects and designated HR personnel (advising the abovementioned group of data recipients) for checking eligibility for certain types of promotion and for – where needed – validation of ASBR awards (purpose A.1)	For purpose (i) the current and previous year, for purpose (ii) up to 10 years of history to achieve more robust and valid insights and recommendations, and for purpose (iii) the current and previous two years (as this allows the determination of eligibility for promotions to the next salary band without recruitment)
Analyses and insights related to salary progression and bonuses	Providing aggregated statistics (non-personal data) and insights to designated HR personnel for assessing the appropriateness of the policies and HR services related to salary progression and bonuses (ASBR) and identify ways to improve them, including the identification of possible biases and solutions to remove them (purpose A.2)	Up to 10 years of history are used to achieve more robust and valid insights and recommendations. For purpose (i) a history of five years is shown. For purpose (ii) the full period available may be used to derive trends and draw more robust conclusions for HR solutions.
Dashboard and reports as well as analyses and insights related to promotions and transfers	Providing personal data about promotions and transfers of staff to line managers, supervisors, and management teams of data subjects, for managing, developing and advising talent and for succession planning^[14], also providing the data to designated HR personnel who are advising managers (purpose A.1) Providing aggregated statistics (non-personal data) and insights to designated HR personnel for assessing the appropriateness of the policies and HR services and identifying ways to improve these, including the identification of possible biases and solutions to remove them (purpose A.2)	For purposes (i) and (ii) the current and previous performance year; and for purpose (iii) up to 10 years of history to achieve more robust and valid insights and recommendations.
Dashboards and reports related to trainings	Providing personal data of staff about trainings to line managers, supervisors, and management teams of data subjects for managing, developing and advising talent, for managing a fair distribution of resources (limited availability of training and time investment) and for resource planning (through absences from work during trainings) (purpose A.1) Providing personal data of staff to designated HR personnel for advising managers and staff regarding skill and competency development (e.g. via the business partner or employee partner function) (purpose A.1) Providing aggregated statistics (non-personal data) to designated HR personnel for assessing the appropriateness of the policies and HR services related to skill development and trainings and identifying ways to improve them (purpose A.2)	For purposes (i) and (ii) the current and previous performance year; and for purpose (iii) up to 10 years of history to achieve more robust and valid insights and recommendations.
Dashboards and reports related to sourcing, recruitment campaigns, and mobility opportunities	Providing an overview of reserve listed candidates to managers and designated HR staff to support sourcing/hiring from the reserve list and resources planning Providing aggregated statistics and operational data about campaigns (both non-personal data) to designated personnel in HR involved in managing and administering the recruitment processes (including mobility opportunities) (purpose A.1) Providing aggregated statistics (non-personal data) to designated HR personnel for assessing the appropriateness of the policies and HR services and identifying ways to improve these (purpose A.2)	For purpose (i), data for up to two years is provided (two years’ validity of reserve list appointments). For purpose (ii), the current year is shown and the previous year as a reference point. For purpose (iii), up to two years of data are used.
Analyses and insights related to sourcing, recruitment campaigns, and mobility opportunities	Providing aggregated statistics (non-personal data) to designated HR personnel for assessing the appropriateness of the policies and HR services and identifying ways to improve them (purpose A.2)	Up to two years of data are used
Reports for the financial compliance check (DG-SE/CGO)	Providing a list of staff with relevant information for determining the risk group^[15] to designated staff in DG-SE/CGO for drawing staff for the compliance check for the private financial transactions exercise (purpose A.1) Providing information about position and active period of a staff members to designated staff in DG-SE/CGO to assess for which periods which private financial transactions have to be checked and providing contact details to DG-SE, who hand-over the information to an external auditor for contacting drawn employees^[16] (purpose A.1)	Data are processed and provided for the last closed calendar year only.

What are your rights?

You have the right to access your personal data and correct any data that are inaccurate or incomplete. You also have (with some limitations) the right to delete your personal data and to object to or to restrict the processing of your personal data in line with the EUDPR. The ECB may restrict your rights to safeguard the interests and objectives referred to in Article 25(1) of the EUDPR.

Who can you contact for queries or requests?

You can exercise your rights by contacting DG/HR via the People Analytics team in the Employee Services Division, at [email protected]. The ECB’s Data Protection Officer at [email protected] answers all queries relating to personal data.

Addressing the European Data Protection Supervisor

If you consider that your rights under the EUDPR have been infringed as a result of the processing of your personal data, you have the right to lodge a complaint with the European Data Protection Supervisor at any time.

For example, a suspected data error may be discussed with the relevant counterpart in the HR Operations team, who may be able to reconcile any errors in the source system.
Predictions are only on an aggregated level. HR Analytics does not predict any individual data points or values, or implement profiling or automated decision-making.
Incidentally and only in rare cases, it cannot be fully excluded that special categories of personal data may be revealed. This applies in two scenarios: (1) if snapshots from a different point in time are used and one or few data subjects have changed their gender in between, and in these cases it is still unlikely that this is revealed to the person processing the data; and (2) if the gender is non-binary, in which case the source system may show as “unassigned” (in this case this would only be revealed in exceptional and unlikely cases and only to the person processing the data); this applies to all use cases where a gender split in the data is needed. These special categories are, however, not revealed to data recipients, unless stated otherwise.
Working time always refers to the planned weekly working time, and more specifically and exclusively to the contractually agreed hours worked per week.
Refers to the type of absence and attendance, duration, and start and end dates.
Administrative sick leave data in this document always includes leave type, start date and end data.
Applicant information refers to all data entered by an applicant in the context of a recruitment procedure at the ECB. This includes, but is not limited to: names, address, phone number, email address, date of birth, gender, nationality, educational background and professional experience.
The EDPS considers administrative sick leave data (start and end date of a sick leave) to be a special category of personal data: https://edps.europa.eu/sites/default/files/publication/12-12-20_guidelines_leave_flexitime_en.pdf
Non-personal data may be shared with other stakeholders for transparency reasons and communication, as decided by DG-HR management.
This process was carried out manually before via Excel, in a labour-intensive way that was also prone to error.
This only refers to ECB employees as data subjects. Applicants cannot be identified in such reports or dashboards.
This is for validation of the data the insurance administrator processes to ensure data accuracy: the administrator sends its records to the ECB for reconciliation (by dedicated ECB HR personnel).
The processing operation relevant to HR Analytics described and assessed in this document ends at the provisioning of data with designated HR personnel in charge of the ASBR calibration. During the calibration meeting, managers only get to see the data of data subjects on lower levels within their business area.
When a staff member leaves the team, succession planning helps prepare for that event and helps select potential successors of the staff member leaving the team.
Based on the position and job, there are different probabilities if a person is randomly drawn for the compliance check. This is fixed by CGO before retrieving the data.
The process of DG-SE/CGO and the external auditor is out of scope for this DPIA and needs to be addressed by DG-SE/CGO in case a DPIA is needed.

Privacy statement for People Analytics (or 'HR Analytics')

What is our legal framework?

Why do we process personal data?

What is the legal basis for the ECB processing your personal data?

1. Dashboards and reports related to leave

2. Analyses and insights related to periods of leave (excluding sick leave)

3. Dashboards and reports as well as analyses and insights related to sick leave

4. Dashboards and reports as well as analyses and insights related to working time and attendances

5. Dashboards and reports as well as analyses and insights related to positions, contracts, and employment

6. Dashboards and reports as well as analyses and insights related to the organisation and role profiles

7. Position Plan simulation tool

8. Strategic Workforce Planning (SWFP) tool

9. SSM rotation tool

10. Dashboards and reports as well as analyses and insights related to demographics and diversity

11. Gender pay gap analyses

12. Projections of the demographical development of the ECB

13. Dashboards and reports as well as analyses and insights related to compensation and benefits

14. Reports related to ECB insurances (health, long-term care, accident)

15. Dashboards and reports related to relatives and associates

16. ASBR calibration tool

17. Dashboards and reports related to salary progression and bonuses

18. Analyses and insights related to salary progression and bonuses

19. Dashboard and reports as well as analyses and insights related to promotions and transfers

20. Dashboards and reports related to trainings

21. Dashboards and reports related to sourcing, recruitment campaigns, and mobility opportunities

22. Analyses and insights related to sourcing, recruitment campaigns and mobility opportunities

23. Reports for the financial compliance check (DG-SE/CGO)

Who is responsible for processing your personal data?

Who will be the recipients of your personal data?

What categories of personal data are collected?

Will your personal data (in a clear or encrypted form) be processed (i.e. transferred, accessed or stored) in third countries or by international organisations?

How long will the ECB keep personal data?

What are your rights?

Who can you contact for queries or requests?

Addressing the European Data Protection Supervisor

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