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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