12 December 2002

HSBC, London


Host: HSBC

Meeting agenda

Welcome & EPON Introduction

Chair: David Trower

• Introduction to EPON
• Themes of the meeting

Exchange of experience on international transfers of personal data from the European Economic Area (EEA)

All Members

  • EPON members’ role within their organisation
  • Their position in the organisation (job title and location within the organisation)
  • Their main responsibilities
  • The countries which fall within their remit
  • Budget 

Development of international transfer policy

All Members

• What are its objectives?
• What assistance, if any, did you seek/receive? From whom?
• Scope of policy
• Content of policy/other documentation
• Implementation/Education
• Assessing whether the policy is being followed in your organisation. Conduct audits? Other?

Contracts, Safe Harbor, and Internal Codes

All Members

  • Contracts
    • EU standard contracts
    • ICC clauses
    • Other national, sectoral or company variations: Changes made, their rationale, and implications of no longer gaining automatic approval by data protection authorities
  • US Safe Harbor
    • Steps required to join the Safe Harbor
    • Advantages / Disadvantages
    • Is it worth the effort?
  • Internal codes
    • Steps involved
    • Advantages
    • Disadvantages
    • Is it worth the effort? 

Data Protection Authority/European Commission Approval

All Members

  • Members’ experience
  • National differences?

Specific issues

All Members

  • Examples such as staff travelling with laptops
  • What precautions are taken?
  • What guidance is given?
  • Other problem areas?

European Commission’s 2nd stage consultation of social partners on The Protection of Workers’ Personal Data (published 31st October 2002)

Nicola Fenny, Senior Policy Advisor, Confederation of British Industry

  • Consent
  • Medical data
  • Drug testing and genetic testing
  • Monitoring and surveillance
  • National legislation
  • International instruments eg. ILO Code and the Council of Europe’s Recommendation
  • Art. 29 DP Working Party’s Opinion