Article 14 Notice

PolicySpeak operates a professional platform for monitoring European Union legislative and media developments. To do so, we collect and process information published by the EU institutions, by the EU Transparency Register and by press sources. That information includes personal data — usually your name, your function, and the positions you have expressed publicly in the exercise of that function.

We did not obtain it from you. This notice informs you of that processing and of your rights, in accordance with Article 14 of Regulation (EU) 2016/679 (GDPR).

We are not established outside the European Union and therefore do not appoint a representative within the meaning of Article 27 GDPR.

We pursue the following purposes:

• tracking European Union legislative procedures — committee work, votes, amendments, procedural stages, implementing acts — and making them searchable;
• monitoring press coverage of the files our clients follow;
• scoring the relevance of tracked developments against the public-policy priorities configured by each client;
• compiling, for a named public office-holder or registered interest representative, a consolidated view of the files they have handled, the positions they have publicly taken and the votes they have cast, each element linked to the public source it comes from;
• producing, at our clients' request, summaries, notes and draft documents with links to sources, intended for human review;
• supporting research, statistical analysis and reporting on the European legislative process;
• keeping a copy of what we delivered to a client and when, so that we can evidence it, handle a request for correction, and defend a claim; and
• maintaining, over time, a faithful record of European legislative activity — which file was handled by whom, which position was taken, which vote was cast and when — so that the public decision-making process remains verifiable after the event.

These services are supplied to professional organizations under a paid subscription.

3.1 General basis

The processing is based on Article 6(1)(f) GDPR — legitimate interests. The legitimate interests pursued are:

• PolicySpeak's interest in carrying on a lawful economic activity of reporting on the European legislative process;
• our clients' interest in following, reliably and with sources, a public decision-making process that concerns them;
• the general interest in the traceability and intelligibility of the European legislative process and of the interest-representation activity surrounding it.

We have balanced those interests against your rights and freedoms. We concluded that the data processed relate exclusively to the exercise of a public function or of a declared interest-representation activity, that they were published by the institutions themselves or by you, and that they do not touch on your private life.

3.2 Data revealing political opinions, and how we separate what we hold

Some of the information we process — a recorded vote, a publicly stated position, membership of a political group — reveals political opinions and is therefore a special category of personal data within the meaning of Article 9(1) GDPR. What we hold is kept apart according to how it reached us, and the parts are not subject to the same rules.

Who you are and what office you hold. Your name, date of birth and nationality; the fact that you hold a mandate, sit on a given committee, were appointed rapporteur on a file, or are registered in the Transparency Register under a given number; the fact that you met a given interest representative on a given date about a given file; and the professional address the institution publishes for you. None of this reveals an opinion, and we treat it as ordinary personal data under Article 6(1)(f) GDPR. Where the institution publishes your professional contact details, we may show them to our clients.

What you did and said in public. Everything here has two features at once: it is something you did in public, and it reveals a political opinion. Your recorded votes, the amendments you tabled, the documents you authored or signed which state a position, your political group, what you said in a publicly broadcast committee or plenary sitting, what you published on a public account, and what a press publication attributes to you in your own words. Each of these is an act you performed in public. We process them under Article 9(2)(e) GDPR — data manifestly made public by the data subject. We may organize them by person, and we may calculate values from them, such as counts, rates and proportions, provided the calculation is deterministic, you can reproduce it yourself from the same public sources, and every element is displayed with a link to the source it comes from.

What others wrote about you. Press analysis, commentary, and a third party's account of your position. This is not something you made public: it is what someone else said about you. We use this material to report on legislation — what a proposal contains, how a procedure is moving, how a text is being criticized, how a sector is reacting. We link press coverage to the people it mentions so that our clients can find it, always with attribution and a link to the source, and we remove such links on justified request. We do not derive our own assessment of your positions from what others have written about you. Where a press item quotes your own words exactly, or reports as a fact a vote you cast or an act you took, that part counts as something you said or did in public (the category above). A journalist's or anyone else's description, summary or paraphrase of your views never does.

We also produce assessments about you, and you should know exactly what that means. Alongside calculated values — counts, rates and proportions, which you can recompute yourself — we produce assessments: how you have positioned yourself on a policy area, on the evidence of what you have done in public. These are our opinion, not a statement of fact about you, and we present them as such. Assessments look backwards, at positions you have already taken. Three rules apply to all of them: they are derived only from what you have said and done in public (your own words, quoted exactly, and your votes and other acts) and never from a third party's description, summary or paraphrase of your views; every one is displayed with a link to each item it is derived from, so you can see what it is based on; and none of them is a decision about you — our clients are required to look at the underlying sources and to have a person reach their own conclusion.

If you disagree with an assessment. Tell us. Where it rests on a fact that is wrong, we correct the fact and recompute. Where you contest the assessment itself, we record it as disputed, show that alongside it, have a person review it, and reply to you with reasons within one month. We can also remove an assessment concerning you entirely while keeping the factual record — your votes and positions stay, our reading of them goes. See point 10.

We do not create any record, flag or field about criminal convictions or offences concerning any person. Press coverage we monitor may report on such matters; we make reasonable efforts to keep it out of what we show about a person, and we remove it from a person's page on justified request.

Our clients are contractually prohibited from making our outputs public, from attributing to us any assessment or projection concerning you that we have not supplied, from compiling any record of criminal convictions or offences, from taking a decision producing legal effects concerning you or similarly significantly affecting you on the basis of our outputs without human review, and from using them in a manner constituting discrimination on the basis of political conviction. Any conclusion a client draws for itself from the public record or from its own sources is its own, made under its own responsibility, and may not be presented as ours.

3.3 Long-term preservation

Part of what we hold is a record of public decision-making: who was rapporteur on a file, how a vote was cast, which position was publicly defended and on what date. We keep that record for the long term, and in principle without a fixed end date, because its usefulness is inseparable from its continuity. A position taken in one parliamentary term is often only intelligible against one taken in another, and a person who leaves public office may return to it years later. Deleting the record would not protect anyone: it would simply make the public process unverifiable after the event.

That long-term preservation is carried out in accordance with Article 5(1)(e) and Article 89(1) GDPR, and is subject to the safeguards described in point 8.

What we keep of what we send. When we deliver a briefing or a profile to a client, we keep a copy of it. That copy records what was sent and when. We keep it so that we can evidence what we delivered, deal with a request to correct something, and defend a claim if one is brought. It is not searchable by person, it is never sent to another client, and it is never used to produce anything new. If we correct something about you, we do not alter a copy already delivered — that would destroy its value as a record of what was sent — but we attach a correction note to it, and from then on that copy is used only for the purposes just described.

What our clients put in. Our clients record their own priorities, their own lists of people they follow and their own notes in areas of the platform reserved to them. That material belongs to the client, who is responsible for it. It is never merged into what we hold about you, never shared with another client, and never combined across clients. It is not used to correct or add to our own record of you.

All the data we process come from publicly accessible sources. We carry out no collection from you, nor from private third parties.

• public registers and document databases of the European Parliament, in particular the register of documents, minutes and published roll-call votes;
• registers and publications of the Council of the European Union and of the European Commission;
• EUR-Lex and legislative procedure tracking databases;
• publicly broadcast recordings of committee and plenary proceedings;
• the EU Transparency Register;
• public accounts of the persons concerned, where they publish under their own name;
• press publications and publicly accessible news sources.

The first six sources listed feed the record of who you are and of what you did and said in public (the first two categories at point 3.2). Press and other third-party sources feed that record only where they carry your own words, quoted exactly and attributed to you, or report as a fact a vote you cast or an act you took, such as tabling an amendment or signing a letter. Everything else they contain is held as what others wrote about you (the third category at point 3.2).

The sources in detail

As at the date of this version, we ingest the following sources.

European Parliament. The Parliament's Open Data API (Members, procedures, plenary agendas and roll-call votes); the Legislative Observatory (OEIL); the eMeeting committee agendas; the Parliament's website, including committee pages, Members' pages and the meetings with interest representatives that Members declare there, and its press and committee news feeds; the webstreaming and video-on-demand service, for recordings of its public meetings; and the publications of the European Parliamentary Research Service.

Council of the European Union and European Council. The Council's public register of documents and its document server; its live video service, for recordings of public sessions; and its press releases.

European Commission. The Have Your Say portal (Better Regulation), including the feedback published there; the register of delegated and implementing acts; the Comitology Register; the Register of Commission Expert Groups; the Register of Commission Documents; the Commission work programme and the State of the Union letter of intent; the Commission's website, including the pages of the College and of each Commissioner; and the Press Corner and the news feeds of the Directorates-General.

Across the institutions. The Publications Office's Cellar repository, which holds the EUR-Lex collection; the EU Whoiswho official directory; the EU Law Tracker; the EU Transparency Register; and the news and press feeds of EU agencies, bodies and joint undertakings, the European Economic and Social Committee, the Court of Justice, the European Central Bank, the European Investment Bank, the European Ombudsman, the European political parties and the Parliament's political groups.

Public accounts. Bluesky accounts of EU institutions, political groups, agencies, media, journalists, think tanks, trade bodies, civil-society organizations and trade unions, and the verified Bluesky accounts of current Members of the European Parliament and Commissioners.

Press and other publications. News feeds, newsletters and public listing pages in these categories: EU-focused media and the EU sections of international outlets; the politics and EU desks of the national press of the Member States; sector and trade press; think tanks and research institutes; trade associations and industry bodies at EU and national level, including the joint letters they publish; NGOs, consumer organizations and trade unions; the governments, parliaments and regulators of the Member States, and United Kingdom government departments and regulators; international bodies such as the WTO, the OECD and the WHO; legal commentary; and public event listings. To reach outlets that publish no feed of their own, we also use the GDELT news database and targeted Google News searches.

Wikidata, only to cross-check who currently represents each Member State in the European Council.

• our subscribing clients, professional organizations bound by a contractual duty of confidentiality and by use restrictions. They may share our outputs with their own members. Our outputs are never made available to the public;
• our technical suppliers acting as processors: hosting and infrastructure, providers of artificial-intelligence services for the generation features, email delivery, support and billing.
• public authorities, where the law requires us to disclose.

Some of our processors, in particular providers of artificial-intelligence services, process data outside the European Economic Area. The countries concerned are:

• United States — providers of artificial-intelligence services (text generation, scoring and search indexing), email delivery, and application error monitoring. The safeguards named in these providers' terms are the European Commission's standard contractual clauses (Article 46(2)(c) GDPR) and, for a provider certified under it, the EU-US Data Privacy Framework (the European Commission's adequacy decision of 10 July 2023, Article 45 GDPR).
• People's Republic of China — a provider of artificial-intelligence services used to classify, summarize and score the press and institutional items we ingest.

You can obtain a copy of the safeguards that apply to a given transfer by writing to us at the address given in point 1.

We hold your data in distinct retention layers, which are not kept for the same time and are not used for the same thing. This distinction is separate from the classifications described at point 3.2, which concern the basis of the processing rather than its duration.

• The monitoring layer — the working data that supports tracking, scoring, alerting and the production of briefings — is kept for as long as a procedure is tracked and for ten years after it closes.
• The record layer — who handled which file, which position was publicly taken, which vote was cast and when — is preserved for the long term and in principle without a fixed end date, on the basis set out at point 3.3. It contains only the record of who you are and of what you did and said in public, as it appears in the official public record: it is not enriched from any other source, and no characterization of you generated by PolicySpeak is added to it.
• Data taken from the EU Transparency Register are kept for as long as the organization concerned is registered and for ten years afterwards in the monitoring layer; the record of which registered entity engaged on which file is preserved in the record layer. Contact details are deleted as soon as the registration ends.
• Press items are kept in full for ten years, subject to the terms on which each source is licensed or otherwise lawfully retained. After that we keep only the link, the name of the outlet and the date of publication.
• A copy of each briefing or profile delivered to a client is kept for ten years from the date it was sent, and is then deleted. Where it contains material provided by the client, it is deleted with the client's data at the end of the contract.
• If you object to our processing and we uphold your objection, we keep a minimal record — an identifier and the date — for as long as we continue to collect from these sources, so that your data are not collected again. That record is used for no other purpose.

We carry out profiling within the meaning of Article 4(4) GDPR.

We take no decision based solely on automated processing which produces legal effects concerning you or similarly significantly affects you, within the meaning of Article 22 GDPR. Our clients are contractually required to consider the underlying sources and to have a person with authority to reach a different conclusion do so before acting.

We do produce assessments concerning named office-holders, as described at point 3.2. They are derived only from what you have said and done in public, never from a third party's description, summary or paraphrase of your views, and each is displayed with links to the items it is derived from. Calculated values — counts, rates, proportions — are deterministic and reproducible by you from the same public sources.

Our outputs are generated with the assistance of artificial-intelligence systems and are intended for human review.

Our clients are contractually prohibited from taking, or materially basing, a decision producing legal effects concerning you or similarly significantly affecting you on our outputs without human review, and from using them in a manner constituting discrimination on the basis of political conviction.

You have the following rights, under the conditions set out in the GDPR:

• right of access to your data (Article 15);
• right to rectification of inaccurate data (Article 16) — to which we attach particular importance, since our outputs cite attributed positions and contain our own assessments. A fact that is wrong is corrected and anything derived from it recomputed. An assessment is not a fact and cannot be true or false in the same way, so where you contest one we record it as disputed, show that alongside it, and have a person review it. Where we rectify, suppress or withdraw, we notify our clients under Article 19 GDPR and ask them to apply it without undue delay;
• right to erasure (Article 17);
• right to restriction of processing (Article 18);
• right to data portability (Article 20), where it applies.

Your right to object is set out separately at point 11, as Article 21(4) GDPR requires.

Some of these rights are limited in respect of the record layer described at point 3.3. Articles 17(3)(d) and 89 GDPR, and Title 4 of the Belgian Act of 30 July 2018, provide that the rights to erasure, rectification, restriction and objection do not apply, or apply only in part, where they would make it impossible or seriously impair the preservation of a record kept in the public interest. We assess every request individually and explain our reasoning. To exercise these rights, write to us at the address given in point 1.

You have the right to object, at any time, to our processing of your personal data.

This right is set out in Article 21 of the GDPR. You may exercise it by writing to us at the address given in point 1. Please tell us the grounds relating to your particular situation and we will stop the processing unless we can demonstrate compelling legitimate grounds which override your interests, rights and freedoms. We respond within one month.

If we uphold your objection, we stop and we keep a minimal record so that your data are not collected again at the next ingestion. That record is used for nothing else.

You may lodge a complaint with a supervisory authority, in particular with the authority competent for PolicySpeak:

Data Protection Authority — Autorité de protection des données / Gegevensbeschermingsautoriteit, Rue de la Presse 35, 1000 Brussels — contact@apd-gba.be

You may also contact the supervisory authority of your Member State of residence or place of work.

Article 14 GDPR requires us to inform you where we obtain your data from third parties. Article 14(5)(b) provides that this information may be given publicly where individual notification would involve a disproportionate effort, provided the controller takes appropriate measures to protect your rights.

We carried out that assessment, category by category, and decided on public information through this page. We accompany that information with the following measures: architectural separation of the classification described at point 3.2, minimization of the data collected, assessments derived only from the person's own public words and acts and always linked to their sources, a contestation procedure and the ability to suppress an assessment while keeping the factual record, limited retention periods, notification of rectifications to our clients, restricted distribution (our outputs reach only subscribing organizations and, where applicable, their members, and are never released to the public), and contractual restrictions on our clients' use of our outputs.