Hi, Gabor,

 

Is there a problem for you starting STAR II at the beginning of June?

 

Best.

 

David

 

 

From: <star-bounces@listserv.vub.ac.be> on behalf of Gábor Kulitsán <kulitsan.gabor@naih.hu>
Organization: NAIH
Date: Friday, 13 April 2018 at 10:48
To: 'Lina JASMONTAITE' <Lina.Jasmontaite@vub.be>
Cc: "star@listserv.vub.ac.be" <star@listserv.vub.ac.be>
Subject: Re: [star] STAR II: preparation of the GA

 

Dear Lina,

Dear All,

 

Our bank details have been validated, so we added the bank details in the EC portal and we also signed the DoH.

Taking into account your comments I would suggest 9th or 16th July to start the project. If it is OK for you I will set it in the system.

If you have no objections, we would host the Kick-off Meeting of STARII with pleasure, but if you have any suggestions, please let us know.

 

Best,

Gábor

 

 

From: Lina JASMONTAITE [mailto:Lina.Jasmontaite@vub.be]
Sent: Tuesday, April 10, 2018 5:32 PM
To: Kulitsán Gábor <kulitsan.gabor@naih.hu>; Filippo.Marchetti@trilateralresearch.com
Cc: star@listserv.vub.ac.be
Subject: Re: [star] STAR II: preparation of the GA

 

Dear Gabor and Filippo, 

 

Many thanks for your input. We will adapt Annex B accordingly and upload it not the EC portal by the end of this week. 

Starting the project at the end of June may be problematic for VUB as we are going to host the third summer school on data protection. 

The beginning of June or mid July would be better for us. 

 

Best regards,

Lina Jasmontaite

Doctoral researcher 

Law, Science, Technology and Society (LSTS)

Vrije Universiteit Brussel (VUB)  

Brussels Privacy Hub (BPH)  

Room 4B306, Pleinlaan 2, 1050

Brussels, Belgium

 

www.vub.ac.be/LSTS/ || www.vub.ac.be || www.brusselsprivacyhub.org





 

On 10 Apr 2018, at 16:04, Kulitsán Gábor <kulitsan.gabor@naih.hu> wrote:

 

Dear Lina,

 

Thank you for your e-mail. Here are our answers:

 

  1. Missing info in the PP: Details of NAIH department that is going to carry out the project are added. As I informed you last week we have not signed the Declaration of Honour yet because of the followings: we could not select our Bank Account in the EC Portal yet, because first we had to update our organisation’s data on the Participant Portal by uploading the duly completed Financial Identification form. We did this last Friday, but the validation of this bank account may take a few days. Once it is validated we will select it in the EC portal, and then we will validate the partner summary info and we will also sign the Declaration of Honour. I already asked the PO (Anne De Wolf) and the Validation Service (Kim Schotanus) whether we can or have to sign the DoH without our bank details being verified, but I have not received any answer so far.

 

  1. Starting date of the Project: We also would suggest to start the project earlier than August. Last week of June may be appropriate.

 

  1. Scope of the Project: We agree with Filippo’s suggestion.

 

  1. Hotline: NAIH will not be able to operate the hotline in multiple Languages. English (and Hungarian of course) is OK, but it is unfortunately highly unlikely that we will have / we can find such colleagues who know other languages at a high level. Because it is essentially a pilot project, we plan to operate the hotline for 12 months for a start. First we have to see whether it is worth to be operated or not, and if it will be successful and there will be a need for it, it can be operated longer of course.

 

  1. Results: We agree with Filippo’s suggestions and of course we can incorporate the content of the Project’s website on NAIH’s website.

 

Best,

Gábor

 

 

From: star-bounces@listserv.vub.ac.be [mailto:star-bounces@listserv.vub.ac.be] On Behalf Of Filippo Marchetti
Sent: Monday, April 9, 2018 12:05 PM
To: Lina JASMONTAITE <Lina.Jasmontaite@vub.be>
Cc: star@listserv.vub.ac.be
Subject: Re: [star] STAR II: preparation of the GA

 

Dear Lina, 

 

Thank you for your email. Please find TRI's answers enclosed. 





Part A: the missing points include:

  • TRI validation of PIC status, so far it’s marked as DECLARED

TRI-IE is now validated. Should the system still show differently, please let us know.





  • Starting date of the project: it can be the first day of the month after the entry into force of the GA or we can agree on a fixed starting date. We prepared timeline projections of STAR and STARII projects in order to see ‘peak times’. We consider August to be the most optimal date for starting STARII.

We would strongly advise in favour of June as a starting month for the following reasons:

  • The first operative Workstream of the project regards the mapping of stakeholder needs. August would not be the best month to commence a stakeholder mapping activities due to holidays and conflicting deadlines.
  • We have the impression that the EC approved this project so quickly for us to start asap. While May is not feasible for us, we would be able and prefer to start on 1 June.
  • The stakeholder mapping activities of STAR will be concluded by the end of May. Therefore, following up sooner with other interviews in a new project will help us consolidate our contacts with DPAs and DPOs.

 





Part B: we have prepared a draft Annex B. For it to be completed we need to agree upon changes that we are going to make in the DOW based on the comments provided in the evaluation form. These comments concern:

The scope of the project: 

 

  • The geographical spread of the proposal is not very clear. How are you going to benefit all SMEs and data protection authorities in all EU Member States if the practical activities are targeting one single Member State (Hungary), and indirectly others?
  • The target group is very broad, consisting of all SMEs in the EU, on the one hand, and data protection authorities on the other hand. How could we explain t this approach and what is the benefit of providing such a Europe-wide effort?
  • It is difficult to understand in the way the project is written, whether the specific activities of the project target only Hungarian SMEs or all SMEs in the EU.

We suggest to add a few lines describing how we will identify our target for interviews and for the other activities, such as by identifying key industries and business sectors to ensure a consistent efficacy of the services. This would both serve as a reassurance for the EC that the project is targeting the EU and not just Hungary, and at the same time it would cast light about how we aim to achieve a broad beneficial effect across sectors.





The hotline:

 

  • This activity is not entirely convincingly presented. It is stated that the hotline will be operated in English and Hungarian, with other languages on needs basis. The results of the hotline questions will again form a basis for research activity.
  • The e-mail based "hotline" is planned for one year, and it is not clear whether or how it will continue.

 

We suggest to reassure them that the hotline will be operated by NAIH but that the other partners will support NAIH in answering questions in other languages. We suggest to make some examples of other languages we speak in the consortium, such as Dutch, Italian, German …





Results:

 

  • The EU-wide general handbook for SMEs raises challenges in terms of addressing a wide variety of fields and types of SMEs in various countries, which means the handbook remains quite general in nature and thus might duplicate the already existing (CoE/FRA general handbook). There are also some national differences in implementation of data protection rules that the project might not consider fully.

We are not sure that we should systematically consider all national implementing legislation to the GDPR, as it would broaden the scope of our handbook research beyond our capabilities. What we could do is to decide 2-3 legal systems to focus on and compare when it comes to analyse rules that need national implementation.

 

With regard to the risk of an overlap with the CoE general handbook, we could underline that our approach would be different: while that handbook is mainly focused on giving a plain overview of the legislation, basically repeating the legislation, ours would tackle specific issues, such as DPO, DPIAs, the right to be forgotten, etc., based on the responses we collect from SMEs. To put it differently, we could reassure them that our handbook will be an issue-focused handbook rather than a general handbook.

  • The responsibility regarding updating of the handbook is unclear.

We could reassure that the handbook will be updated at the end of the project and that we are confident that at that point it will cover most of the relevant issues.

  • It is quite unlikely that SMEs might read about the project in an academic journal. Relying mainly on academic analysis in the EU as a whole, the needs assessment is not followed by the examination of the specific needs of the Member States.

It is true that SMEs do not read academic journals, but this is not the only way we connect with companies under this project.

  • The project website will be maintained for two years only after the end of the project. It’s suggested to incorporate the content of the website on the NAIH’s website.

We could consider to maintain the standalone website for 4 years, as it happens with other H2020 websites.

 

 

Best wishes, 

 

Filippo

 

 

 

 





Il giorno 05 apr 2018, alle ore 09:25, Lina JASMONTAITE <Lina.Jasmontaite@vub.be> ha scritto:

 

Dear all, 

Almost all information that is necessary for the completion of the grant agreement has been entered into the EC portal.

Part A: the missing points include:

 

  • Details of NAIH department that is going to carry out the project and NAIH’s validation of partner summary info
  • TRI validation of PIC status, so far it’s marked as DECLARED
  • Starting date of the project: it can be the first day of the month after the entry into force of the GA or we can agree on a fixed starting date. We prepared timeline projections of STAR and STARII projects in order to see ‘peak times’. We consider August to be the most optimal date for starting STARII.

 

Part B: we have prepared a draft Annex B. For it to be completed we need to agree upon changes that we are going to make in the DOW based on the comments provided in the evaluation form. These comments concern:

The scope of the project: 

 

  • The geographical spread of the proposal is not very clear. How are you going to benefit all SMEs and data protection authorities in all EU Member States if the practical activities are targeting one single Member State (Hungary), and indirectly others?
  • The target group is very broad, consisting of all SMEs in the EU, on the one hand, and data protection authorities on the other hand. How could we explain t this approach and what is the benefit of providing such a Europe-wide effort?
  • It is difficult to understand in the way the project is written, whether the specific activities of the project target only Hungarian SMEs or all SMEs in the EU.

 

The hotline:

 

  • This activity is not entirely convincingly presented. It is stated that the hotline will be operated in English and Hungarian, with other languages on needs basis. The results of the hotline questions will again form a basis for research activity.
  • The e-mail based "hotline" is planned for one year, and it is not clear whether or how it will continue.

 

Results:

 

  • The EU-wide general handbook for SMEs raises challenges in terms of addressing a wide variety of fields and types of SMEs in various countries, which means the handbook remains quite general in nature and thus might duplicate the already existing (CoE/FRA general handbook). There are also some national differences in implementation of data protection rules that the project might not consider fully.
  • The responsibility regarding updating of the handbook is unclear.
  • It is quite unlikely that SMEs might read about the project in an academic journal. Relying mainly on academic analysis in the EU as a whole, the needs assessment is not followed by the examination of the specific needs of the Member States.
  • The project website will be maintained for two years only after the end of the project. It’s suggested to incorporate the content of the website on the NAIH’s website.

 

Could you please provide your suggestions on how we should address comments made in the evaluation by COB 9 April?

 

 

Best regards,

Lina Jasmontaite

Doctoral researcher 

Law, Science, Technology and Society (LSTS)

Vrije Universiteit Brussel (VUB)  

Brussels Privacy Hub (BPH)  

Room 4B306, Pleinlaan 2, 1050

Brussels, Belgium

 

 

 

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