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Europaudvalget 2007-08 (2. samling)
KOM (2007) 0185 Bilag 5
Offentligt

COMMISSION OF THE EUROPEAN COMMUNITIES

Brussels, 16.1.2008

SEC(2008) 29/2

CORRIGENDUM:

Annule et remplace le document SEC(2008) 29 du 11.1.2008,

transmis par erreur sans annexes.

COMMISSION STAFF WORKING DOCUMENT

Report on the Outcome of the Public Consultation on the Review of Regulation (EC) No

1049/2001 regarding public access to European Parliament, Council and Commission

documents

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COMMISSION STAFF WORKING DOCUMENT

Report on the Outcome of the Public Consultation on the Review of Regulation (EC) No

1049/2001 regarding public access to European Parliament, Council and Commission

documents

NTRODUCTION

On 9 November 2005, the Commission decided, as part of its “European Transparency

Initiative”

, to launch the review of Regulation (EC) No 1049/2001 regarding public access to

European Parliament, Council and Commission documents

. This decision anticipated a

European Parliament Resolution adopted on 4 April 2006, inviting the Commission to come

forward with proposals for amending the Regulation

. As a first step in the review process,

the Commission held a public consultation on the Regulation on the basis of a Green Paper

published on 18 April 2007.

The Green Paper and the contributions received from citizens as well as from public and

private bodies are available on a dedicated website

. The purpose of this report is to provide

an overview of the reactions received from citizens, public bodies and civil society and to put

them into perspective. This report does not anticipate proposals which the Commission will

submit in due course with a view to amending the Regulation on public access to documents.

ONTRIBUTIONS TO THE PUBLIC

ONSULTATION

The Commission received a total of eighty-one contributions to the Green Paper,

from civil society (30), public authorities (25), the corporate world (14), and

individual citizens (12). With regard to this last category, the Commission has

received a number of reactions from citizens, which did not concern the working and

the review of the rules on public access but addressed other issues, e.g. the technical

set-up of websites. These contributions have not been taken into account in the

assessment of the public consultation on Regulation 1049/2001.

At the start of the consultation period, a seminar organised by the Brussels based

NGO

European Citizen Action Service

(ECAS) on 19 April 2007 enabled the

Commission to explain the purpose of the Green Paper and to collect first reactions

on how civil society perceived the working of the rules on access to documents of the

European institutions.

In addition, several events were organised by Commission representations in a

number of Member States, through which opinions from national civil society

organisations, the local press, policy makers and other stakeholders were collected.

Minutes of the Commission's meeting No 1721 of 9 November 2005, item 6; see also documents

SEC(2005) 1300 and SEC(2005) 1301

OJ L 145 of 31.5.2001, page 43

P6_A(2006) 052

http://ec.europa.eu/transparency/revision/index_en.htm

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Annex 1 contains a detailed list of respondents per category and subcategory and of

events organised in the Member States.

OSITIONS ON THE

SSUES RAISED IN THE

REEN

APER

The replies given and positions taken by the respective categories of respondents to

the questions in the Green Paper can be summarised as follows. In each paragraph, a

reference is made to the corresponding question in the Green Paper.

2.1.

Information provided through registers and on the websites (question no 1)

In all four categories of respondents, a large majority considers that information is

difficult to find on the registers and websites. For half of these respondents, the scope

of these registers and websites is also insufficient.

More specifically, the following comments and suggestions were made:

•

a single access point with links to the relevant websites would be useful; site maps

could also be improved;

•

more documents should be available in full text;

•

documents should be available in more languages.

2.2.

Active dissemination of information (question no 2)

The vast majority of

civil society

organisations are in favour of more active

dissemination of information. However, two NGOs express reservations. The

German Civil Liberties Union and Statewatch stress the need for enhanced passive

transparency.

Public bodies

unanimously support a more pro-active transparency. The Czech

Senate and the Finnish Government call for direct access to documents having an

impact on the legislative process. The House of Lords and the French Government

suggest setting up an "alert service" to which users could subscribe.

The corporate sector,

in particular the representatives of the chemical and

biotechnological industries, sees no need for such a policy and fears uncontrolled

spreading of confidential business information.

Citizen respondents

are divided on this issue. One half would welcome a more

active dissemination. The other half either fails to see a need for such a policy or

shares the reservations expressed by the two NGOs mentioned above.

2.3.

A single set of rules for access to documents, including environmental

information (question no 3)

Civil society

is almost unanimously in favour of aligning Regulation 1049/2001 with

the provisions of the Århus Convention regarding access to information in

environmental matters. The German Civil Liberties Union and the Portuguese

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Consumer Organisation FENACOOP are of the opinion that a specific framework for

access to environmental information is justified.

Two thirds of the

public bodies

also support a single regime for access to documents

or information. This view is not shared by the European Ombudsman or by the

Governments of the Czech Republic, Denmark, France and Hungary, who consider

that merging the two regimes is neither necessary nor desirable.

The

corporate world

is generally not in favour of integrating access to

environmental information into the general system. The chemical and

biotechnological industries consider that the provisions stemming from the Århus

Convention should remain a "lex specialis" vis-à-vis the general Regulation on

public access. They are particularly concerned with regard to the protection of

intellectual property rights, which they believe might be endangered by integrating

access to environmental information into the general access regime.

The majority of

citizen respondents

are in favour a single access regime as it would

provide more clarity and legal certainty.

2.4.

Transparency and the protection of personal data (question no 4)

It is to be noted that the replies to this question were given before the Court of First

Instance delivered its judgment in the

Bavarian Lager

case. In this judgment, the

Court ruled that the exception aimed at protecting personal data laid down in Article

4(1) (b) of Regulation 1049/2001 only applies where disclosure would concretely

and effectively undermine the privacy or the integrity of the person concerned. When

access to a document containing personal data is requested, the application should be

assessed under the provisions of Regulation 1049/2001. If disclosure would not

affect the person's privacy or integrity, there is no need to examine whether

disclosure meets the criteria of Regulation 45/2001.

Civil society

organisations are generally of the opinion that data protection rules

should not prevent the disclosure of names of individuals acting in an official

capacity or on behalf of their organisations.

The public sector

generally shares this view. The European Ombudsman and the

Swedish Ministry of Justice in particular consider that refusal to disclose personal

data must be based on concrete harm to the individual concerned. In their view, there

is no need to amend Regulation 1049/2001 or the Regulation on the protection of

personal data. The UK Government believes that, once the case law has clarified the

relation between the two potentially conflicting rights, the provision in Regulation

1049/2001 [Article 4(1) b] should be revised. Some public authorities, in particular

the French and Polish Governments, consider that expunging documents for personal

data before disclosure is a satisfactory way to reconcile both rights.

The corporate sector

stresses the need for adequate protection of personal data. The

biotechnological industry points out that some of their employees have been subject

to criminal acts.

Case T-194/04, The Bavarian Lager Co. Ltd / Commission, judgment of the Court of First Instance of 8

November 2007, not yet reported

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The European Ombudsman and one citizen raise the question of an individual's

access to his own personal data. The Commission's view, until now, has been that

this issue does not fall within the scope of the Regulation, which deals with public

access in general, and that the issue of individual protection and access should be

settled in the framework of the data protection legislation.

2.5.

Transparency and the protection of economic and commercial interests

(question no 5)

Opinions are divided on this issue.

A clear majority of

civil society

organisations expressed the view that more weight

should be given to the public interest in disclosure of company-related information.

They tend to consider that only real business secrets may be withheld. Moreover,

they take the view that information regarding illegitimate behaviour of undertakings

should be made public.

Most

public authorities

take the view that the current system, where the protection

of commercial interests is balanced against the public interest in disclosure, strikes

the right balance. The Slovenian Information Commissioner suggests setting up an

exhaustive list of cases where it would never be justified to invoke professional

secrecy, e.g. the use of public funds or the employment relationship of civil servants.

The Czech Government and the Association of German Judges consider that the

current system does not offer sufficient protection. For the German Judges, the

existing provisions do not adequately protect information that was not supplied

voluntarily.

The corporate world

calls for better protection of confidential business information.

There is particular concern about possible abuses of intellectual property rights and

distortion of competition. The chemical and biotechnological industries point to the

obligations under the WTO Trips Agreement. Furthermore, British Telecom

expressed concern with regard to the protection of information supplied under EU

competition rules.

Most

citizen respondents

share the view of civil society that the public interest in

disclosure should prevail.

2.6.

Handling excessive requests (question no 6)

Civil society

is generally opposed to derogations from the normal rules on access

where access requests are excessive. NGOs consider that such derogations would

give the institutions too much discretion. In their view, the problem of voluminous or

excessive requests should be solved through a dialogue between the institutions and

the applicant. Article 6(3) of the Regulation, according to which

"an institution may

confer with applicant informally, with a view to finding a fair solution"

provides for

procedural flexibility in this regard. Two organisations, the Association for

Information Management Professionals (ARMA) and the European Consumers'

Organisation (BEUC) think that there is a case for such derogations. Statewatch is of

the opinion that only extended time frames could be acceptable in exceptional cases.

For the European and Swedish Federations of Journalists on the other hand, the

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current time limit of 15 working days is already too long; they consider 48 hours as a

reasonable time limit.

The public authorities

are divided on this issue, which reflects different practices in

the Member States. In any case, even those Governments which are in favour of

derogations for excessive requests consider that they must be based on objective

criteria. The European Ombudsman shares the view of civil society and considers

that the current provision in Article 6(3) is sufficient to address the problem; he

further considers that the institutions should allocate adequate resources to document

and information management and to the handling of access requests. The German,

Dutch, Slovenian and Swedish Governments also consider Article 6(3) to adequately

address the problem of excessive requests. The UK Government points out that

resources used in dealing with excessive requests preclude institutions from fulfilling

other functions; since resources are not unlimited, a proper balance must be struck.

Both the House of Lords and the UK Government refer to provisions regarding

"vexatious" requests under the UK freedom of information legislation.

The corporate sector

unanimously supports specific measures for handling

voluminous requests. These could consist of asking the applicant to narrow down his

request, extended time frames or setting a maximum number of documents per

application. The chemical industry is concerned about unacceptable disclosure and

calls for an appeal procedure with suspensive effect which would enable companies

to prevent disclosure of confidential business information.

Citizen respondents

are also divided on the issue; one half is opposed for the same

reasons as set out by the NGOs; the other half is in favour but did not elaborate on

the reasons for this opinion.

2.7.

The concept of "document" in relation to databases (question no 7)

The question was whether the definition of "document" should include sets of

information that can be extracted from electronic databases using existing search and

retrieval tools.

Civil society

organisations unanimously expressed the view that the content of

databases must fall within the scope of the Regulation. Some NGOs and

organisations of journalists consider that the current definition in the Regulation

already covers the content of databases. Most civil society organisations call for a

right of access to information, rather than to documents, regardless how and where

the information is stored. In their joint contribution, nine associations of investigative

journalists contest the condition that the information can be extracted using standard

tools, which in fact corresponds to current practice in the Commission.

Public authorities

also consider that the content of databases falls within the scope

of the rules on public access, even if some governments take the view that the current

definition already includes databases. The Danish, Finnish and Slovenian

Governments share the reservations expressed by the nine associations of

investigative journalists with regard to the existing search tools for extracting

information from databases. They are concerned that this would create restrictions

for access to information held in databases. The European Ombudsman, who has the

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same concern, suggests establishing a general obligation to take into account the

needs of transparency in the design and operation of databases.

The

corporate sector

considers that the rules on public access should cover

information held in databases. They point out that the content of databases should be

protected under the exceptions as any other document.

Most

citizen respondents

are in favour of clarifications with regard to access to the

content of databases. One citizen considers that this is already included in the current

definition.

2.8.

Events before and after which exceptions would or would not apply

(question no 8)

All respondents expressed reservations as regards withholding documents before a

specific event. It is generally considered that this might be in contradiction with the

harm test requirement under the Regulation and would nullify the overriding public

interest test.

On the other hand, there is wide support for setting times frames after which

documents become public, well before the 30-year time limit after which archives are

open to the public.

THER

OMMENTS

Three major issues were raised by respondents in their general comments.

3.1.

The scope of the Regulation:

Many NGOs and some public authorities consider that the scope of the Regulation

should be extended to documents held by all institutions and bodies of the European

Union. It should be noted that under the current treaty provisions, there is no legal

base for such an extension, but the Lisbon treaty contains provisions to address this

issue.

3.2.

Documents originating from Member States:

The European Ombudsman, the Finnish and Swedish Governments and Statewatch

ask for a review of the Member States' ability to oppose disclosure of their

documents. The German Government considers that an obligation for Member States

to state reasons for refusal is a conceivable approach. The Commission did not

expressly address this issue in the Green Paper as it is currently pending before the

Court of Justice. It was however mentioned as a consequence of aligning the

Regulation on the requirements of the Århus Convention.

3.3.

The public interest override:

Statewatch regrets what it considers to be an excessively restrictive interpretation

given by the Court of First Instance to the overriding public interest in recent

judgments. Statewatch and ECAS as well as the Finnish Government call for a

clarification of what would constitute a public interest that would prevail over

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exceptions to the right of access. More civil society organisations would like the

public interest test to apply to all exceptions.

ONCLUSIONS

The analysis of the contributions leads to the following main conclusions.

4.1.

Active dissemination of documents

Registers and websites should be easier to access and more harmonised. The public

would welcome a more pro-active disclosure policy.

4.2.

The relation between Regulations 1049/2001 and 1367/2006 (implementing the

Århus Convention)

Aligning Regulation 1049/2001 with the provisions of the Århus Convention on

access to environmental information is widely supported by public bodies and

individual citizens. Environmental NGOs have some concern that such an alignment

might lower the transparency standard for environmental matters. The chemical and

biotechnological industries consider that the Århus provisions should remain a "lex

specialis" vis-à-vis the general rules on public access.

4.3.

The protection of personal data under Regulation 1049/2001

Many respondents, in particular NGOs and journalists, call for greater openness

where persons act in a public capacity. This issue will be reviewed as a follow-up to

the judgment of the Court of First instance in the Bavarian lager case.

4.4.

The protection of commercial interests

Public authorities consider that the current rules strike the right balance. Journalists,

NGOs and a clear majority of citizens claim that more weight should be given to the

interest in disclosure. Industry calls for better protection of business information.

4.5.

Handling excessive requests

The question whether institutions should be able to derogate from the normal rules

when dealing with excessive requests also led to diverging reactions. The private

sector is unanimously in favour. A slight majority of those Member States which

replied to the Green Paper, support specific measures for such requests, based on

objective criteria. The Ombudsman, other Member States and NGOs are opposed to

specific rules on excessive requests.

4.6.

The concept of "document"

As regards the concept of "document", the general feeling is that the current wide

definition should be maintained. A clarification with regard to databases as suggested

in the Green Paper would be welcomed.

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4.7.

Temporal application of exceptions

There is no support for the idea of defining events before which documents would

not be accessible. On the other hand, NGOs and a majority of Member States would

welcome the systematic disclosure of documents after specific events and well before

the 30-year limit for opening the archives.

EXT STEP IN THE

EVIEW PROCESS

The Commission will submit to the European Parliament and the Council a proposal

for the amendment of Regulation 1049/2001 in the course of the first quarter of the

year 2008.

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Annex 1: Respondents to the Green Paper

Civil society organisations

Civil rights

– Article XIX

– the German Civil Liberties Union

– ECAS (European Citizens Action Service)

– Statewatch

Charity/Develop

ment

Consumers

– Caritas Europa

– BEUC

(the

Organisation)

– CRIOC/OIVO

Organisation)

European

(Belgian

Consumers'

Federation

– FENACOOP (Portuguese

Consumers' Cooperatives)

– Bankwatch

Corporate/financ

ial

– Corporate Europe Observatory

Environment

and

– the European Environmental Bureau

– the German

Environment

League

for

Nature

– Friends of the Earth Germany

– the German independent

Environmental Matters

– the Finnish

Conservation

Association

Institute

for

Nature

– the International Fund for Animal Welfare

– the Spanish section of the World Wildlife

Fund

General

civil – Civil Society Contact Group

society

– European House (Hungarian civil society

organisations

organisations)

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Information

professionals

– the Association for Information Management

Professionals (ARMA)

– the

Network

Spanish

Documentation Centres

– the

European

Association

Newspaper

European

– the European Information Association

Publishers'

– FFI (German non-profit organisation on data

processing)

Journalists

– the European Federation of Journalists

– the Swedish Association of Journalists

– joint reply from 9

investigative journalism

associations

for

Public

health – Cancer Research UK

organisations

– the European Public Health Alliance

– the Smoke Free Partnership

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Public sector

Governments

– Czech Republic

– Denmark

– Germany

– Finland

– France

– Greece

– Hungary

– Italy

– Latvia

– Netherlands

– Poland

– Slovenia

– Spain

– Sweden

– UK

Parliaments

– the Czech Senate

– the Danish Folketing

– the Swedish Riksdag

– the House of Lords

European bodies – European Ombudsman

Other

– the Information Commissioners of Slovenia

– the Information

German 'Länder'

Commissioners

the

– the German Association of Judges

– the Austrian regional Officers in charge of

equal opportunities and anti-discrimination

– the Association of French Mayors of large

Cities

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Corporate sector

Chemical

and – The Association of the German Chemical

Industry

biotechnological

industries

– Bayer CropScience

– CEFIC

– EuropaBio

– the European Crop Protection Association

– the Romanian Crop Protection industry

Data processing

Industry

and

enterprise

organisations

Law firms

– DATEV ( a German association)

– Wirtschaftskammer Östrerreich

Confederation of Industry)

– the Austrian Bar Association

– Linklaters

– Studio legale de Matteis (Messina, Italy)

Others

– British Telecom

– the European Organisation for Packaging and

the Environment

– Japan Tobacco International

(Austrian

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Events organised in the Member States

Berlin

Seminar with representatives from the public sector, NGOs,

and journalists, organised by the European Movement

(Netzwerk Europäische Bewegung Deutschland) with

participation from the Commission's Secretariat general and

the German Foreign Ministry

Information on the website and mailing to stakeholders

Discussion meeting with representatives of Finnish public

authorities

Round table with stakeholders

Information on the website. The topic was also raised in

special meetings with public authorities, stakeholders and the

media.

Teleconference with representatives of civil society. The

Commission's Secretariat-General and Legal service

participated

Information on the website and mailing to stakeholders

Stakeholders' survey

Public discussion with representatives of NGOs and the public

and private sectors

Sofia

Stockholm

Vilnius

Meetings with NGOs and with a committee of the Bulgarian

Parliament.; the Commission's Secretariat-General participated

Public seminar with participation of public authorities,

academics and journalists

Discussion meeting with representatives from public

authorities and journalists

Bratislava

Helsinki

Lisbon

Ljubljana

Nicosia

Prague

Riga

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NNEX

2 : R

EPLIES TO THE QUESTIONNAIRE OF THE

REEN

APER

Question 1

Would you qualify the information provided through registers and on the websites of the institutions

as:

Categories

Civil society

Civil

Organisations

Rights

Number

of replies

society

Health

Option

Option B

Option

Other

comments

Charity Organisations

Consumer Organisations

Corporate and financial

NGOs

Environmental

Organisations

General civil

organisations

Information management

professionals

Journalists

Public

Organisations

Public sector

National governments

National Parliaments

European bodies

Other public bodies

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Corporate Sector

Chemical

biotechnological

industries

Data processing

Industry and enterprise

organisations

Law firms

Other industries

Citizens

and

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Question 2: Promotion of active dissemination of information

Should more emphasis be put on promoting active dissemination of information, possibly focussed on

specific areas of particular interest?

Categories

Civil society

Civil Rights Organisations

Charity Organisations

Consumer Organisations

Corporate and financial NGOs

Environmental Organisations

General civil society organisations

Information Management professionals

Journalists

Public Health Organisations

Public Sector

National governments

National Parliaments

European bodies

Other public bodies

Corporate Sector

Chemical

industries

and

biotechnological

Number of

replies

Yes

Other

comments

Data processing

Industry and Enterprise Organisations

Law firms

Other industries

Citizens

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Question 3: Integration of the Aarhus Regulation

Would a single set of rules for access to documents, including environmental information provide

more clarity for citizens?

Categories

Civil society

Civil Rights Organisations

Charity Organisations

Consumer Organisations

Corporate and financial NGOs

Environmental Organisations

General

civil

organisations

Information

professionals

Journalists

Public Health Organisations

Public Sector

National governments

National Parliaments

European bodies

Other public bodies

Corporate Sector

Chemical and biotechnological

industries

Data processing

Industry

and

Organisations

Law firms

Other industries

Citizens

Enterprise

society

Management

Number of

replies

Yes

Other

comments

No opinion

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Question 4: Protection of personal data

How should the exception laid down in Article 4(1)(b) of Regulation (EC) No 1049/2001 be clarified

in order to ensure adequate protection of personal data?

Categories

Civil society

Civil

Organisations

Rights

Number

of replies

society

Health

Option

Option B

Option

Other

comments

opinion

Charity Organisations

Consumer Organisations

Corporate and financial

NGOs

Environmental

Organisations

General civil

organisations

Information management

professionals

Journalists

Public

Organisations

Public sector

National governments

National Parliaments

European bodies

Other public bodies

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Corporate Sector

Chemical

biotechnological

industries

Data processing

Industry and enterprise

organisations

Law firms

Other industries

Citizens

and

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Question 5: Protection of commercial and economic interests of third parties

How should the exception laid down in Article 4(2), 1

indent of Regulation (EC) No 1049/2001 be

clarified in order to ensure adequate protection of commercial and economic interests of third

parties?

Categories

Civil society

Civil Rights Organisations

Charity Organisations

Consumer Organisations

Corporate and financial NGOs

Environmental Organisations

General

civil

organisations

Information

professionals

Journalists

Public Health Organisations

Public sector

National governments

National Parliaments

European bodies

Other public bodies

society

management

Number of

replies

Option A

Option B

Option C

Other

comments

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Corporate Sector

Chemical and biotechnological

industries

Data processing

Industry

and

organisations

Law firms

Other industries

Citizens

enterprise

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Question 6: excessive or improper requests

In the light of experiences made so far, is there a case for specific provisions for handling

requests, which are clearly excessive or improper, in particular with regard to time frames ?

Categories

Civil society

Civil Rights Organisations

Charity Organisations

Consumer Organisations

Corporate and financial NGOs

Environmental Organisations

General

civil

organisations

Information

professionals

Journalists

Public Health Organisations

Public Sector

National governments

National Parliaments

European bodies

Other public bodies

society

Management

Number of

replies

Yes

Other

comments

No opinion

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Corporate Sector

Chemical and biotechnological

industries

Data processing

Industry

and

Organisations

Law firms

Other industries

Citizens

Enterprise

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Question 7: databases

With regard to the content of databases, should the concept of "document" cover sets of information

that can be extracted using the existing search tools?

Categories

Civil society

Civil Rights Organisations

Charity Organisations

Consumer Organisations

Corporate and financial NGOs

Environmental Organisations

General

civil

organisations

Information

professionals

Journalists

Public Health Organisations

Public Sector

National governments

National Parliaments

European bodies

Other public bodies

Corporate Sector

Chemical and biotechnological

industries

Data processing

society

Management

Number of

replies

Yes

Other

comments

No opinion

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Industry

and

Organisations

Law firms

Other industries

Citizens

Enterprise

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Question 8: temporal application of the exceptions

Should the Regulation indicate events before and after which exceptions would or would not apply?

Categories

Civil society

Civil Rights Organisations

Charity Organisations

Consumer Organisations

Corporate and financial NGOs

Environmental Organisations

General

civil

organisations

Information

professionals

Journalists

Public Health Organisations

Public Sector

National governments

National Parliaments

European bodies

Other public bodies

Corporate Sector

Chemical and biotechnological

industries

Data processing

society

Management

Number of

replies

Yes

Other

comments

No opinion

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Industry

and

Organisations

Law firms

Other industries

Citizens

Enterprise