[{"data":1,"prerenderedAt":-1},["ShallowReactive",2],{"detail-sidebar-cat-1-en-105":3,"doc-seo-305133-105":53,"doc-detail-305133-en":127},{"code":4,"msg":5,"data":6},0,"success",[7,14,19,24,29,34,39,44,49],{"id":8,"doc_module":9,"doc_module_name":10,"category_name":11,"show_sort_weight":12,"slug":13},11,1,"Template","Presentations",90,"presentations",{"id":15,"doc_module":9,"doc_module_name":10,"category_name":16,"show_sort_weight":17,"slug":18},12,"Resumes",80,"resumes",{"id":20,"doc_module":9,"doc_module_name":10,"category_name":21,"show_sort_weight":22,"slug":23},14,"Invoices",70,"invoices",{"id":25,"doc_module":9,"doc_module_name":10,"category_name":26,"show_sort_weight":27,"slug":28},15,"Posters",60,"posters",{"id":30,"doc_module":9,"doc_module_name":10,"category_name":31,"show_sort_weight":32,"slug":33},16,"Social Media",50,"social-media",{"id":35,"doc_module":9,"doc_module_name":10,"category_name":36,"show_sort_weight":37,"slug":38},17,"Forms",40,"forms",{"id":40,"doc_module":9,"doc_module_name":10,"category_name":41,"show_sort_weight":42,"slug":43},18,"Letters",30,"letters",{"id":45,"doc_module":9,"doc_module_name":10,"category_name":46,"show_sort_weight":47,"slug":48},21,"Paper Templates",5,"papers-templates",{"id":50,"doc_module":9,"doc_module_name":10,"category_name":51,"show_sort_weight":4,"slug":52},158,"General","general-158",{"code":4,"msg":54,"data":55},"ok",{"site_id":56,"language":57,"slug":58,"title":59,"keywords":60,"description":61,"schema_data":62,"social_meta":120,"head_meta":122,"extra_data":124,"updated_unix":126},105,"en","edps-formal-comments-on-additional-set-of-predetermined-questions-etias","EDPS Formal comments on additional set of predetermined questions - ETIAS","","European Data Protection Supervisor (EDPS) provides formal comments on the Commission draft delegated decision specifying the content and format of questions, and establishing an additional set of predetermined answers and questions for the ETIAS application form. The comments focus on aligning question scope with data protection and legal delegation limits, including time periods for prior criminal convictions and how personal data about family members and friends should be handled within the proposed framework.",{"@graph":63,"@context":119},[64,80,102],{"@type":65,"itemListElement":66},"BreadcrumbList",[67,71,74,77],{"item":68,"name":69,"@type":70,"position":9},"https://docshare.wps.com","Home","ListItem",{"item":72,"name":10,"@type":70,"position":73},"https://docshare.wps.com/template/",2,{"item":75,"name":36,"@type":70,"position":76},"https://docshare.wps.com/template/forms/",3,{"item":78,"name":59,"@type":70,"position":79},"https://docshare.wps.com/template/edps-formal-comments-on-additional-set-of-predetermined-questions-etias/305133/",4,{"url":78,"name":59,"@type":81,"image":82,"author":87,"headline":59,"publisher":90,"fileFormat":93,"inLanguage":57,"description":61,"dateModified":94,"datePublished":95,"encodingFormat":93,"isAccessibleForFree":96,"interactionStatistic":97},"DigitalDocument",{"url":83,"@type":84,"width":85,"height":86},"https://docshare.wps.com/thumbnails/edps-formal-comments-on-additional-set-of-predetermined-questions-etias/305133.png","ImageObject",442,249,{"name":88,"@type":89},"Mary Man","Person",{"url":68,"name":91,"@type":92},"DocShare","Organization","application/pdf","2026-10-13","2026-09-19",true,{"@type":98,"interactionType":99,"userInteractionCount":101},"InteractionCounter",{"@type":100},"ViewAction",6,{"@type":103,"mainEntity":104},"FAQPage",[105,111,115],{"name":106,"@type":107,"acceptedAnswer":108},"What is the purpose of the draft delegated decision discussed in the document?","Question",{"text":109,"@type":110},"It specifies the content and format of questions for the ETIAS application form and lays down related additional sets of answers and questions.","Answer",{"name":112,"@type":107,"acceptedAnswer":113},"How does the EDPS assess the proposed time periods for previous criminal convictions?",{"text":114,"@type":110},"The EDPS notes that the draft extends the time periods beyond those in the ETIAS basic act and considers this a contradiction with the delegation limits, urging alignment with the basic act.",{"name":116,"@type":107,"acceptedAnswer":117},"Does the EDPS limit its comments to specific issues?",{"text":118,"@type":110},"Yes. The formal comments focus on provisions relevant from a data protection perspective and do not prevent additional future comments if new issues arise.","https://schema.org",{"og:url":78,"og:type":121,"og:title":59,"og:site_name":91,"og:description":61},"article",{"robots":123,"canonical":78},"index,follow",{"doc_id":125,"site_id":56},305133,1790118861,{"code":4,"msg":5,"data":128},{"doc_id":125,"user_id":129,"nickname":88,"user_avatar":130,"doc_module":9,"category_id":35,"category_name":36,"doc_title":59,"doc_description":61,"doc_content":131,"file_id":132,"file_url":133,"file_type":134,"file_size":135,"view_count":101,"is_deleted":4,"is_public":9,"is_downloadable":9,"audit_status":9,"page_count":47,"language":136,"language_code":57,"site_id":56,"html_lang":57,"table_of_contents":137,"faqs":138,"seo_title":139,"seo_description":61,"update_tm":140,"read_time":73},7421720224475,"https://ap-avatar.wpscdn.com/davatar_276721f389ce27ea32af1340a28f341c","EDPS Formal comments on the draft Commission Delegated Decision on specifying the content and format of the questions and laying down the additional set of predetermined questions  \nTHE EUROPEAN DATA PROTECTION SUPERVISOR,  \nHaving regard to the Treaty on the Functioning of the European Union,  \nHaving regard to Regulation (EU) No 2018/1725 of the European Parliament and of the Council of 23 October 2018 on the protection of individuals with regard to the processing of personal data by the Community institutions and bodies and on the free movement of such data (‘EUDPR’)1, and in particular Article 42(1) thereof,  \nHAS ADOPTED THE FOLLOWING FORMAL COMMENTS:  \n1. Introduction and background  \n1. On 7 July 2022 the European Commission adopted draft Commission Delegated Decision on specifying the content and format of the questions and laying down the additional set of predetermined questions (‘the Proposal’, ‘the draft Delegated Decision’), in relation to the European Travel Information and Authorisation System (ETIAS).  \n2. The objective of the draft Delegated Decision is to specify the content and format of the questions and to lay down the content and format of related additional sets of answers and questions, part of the ETIAS application form to be completed by each applicant. These question relate to criminal offences, stays in specific war or conflict zones and decision(s) to leave the territory or to return.  \n3. The Proposals are adopted pursuant to Article 17(5) and (6) of Regulation (EU) 2018/1240 of the European Parliament and of the Council2 (‘ETIAS Regulation’).  \n4. The EDPS previously issued Opinion 3/2017 on the Proposal for a European Travel Information and Authorisation System (ETIAS)3, as well a number of formal comments on the various implementing and delegated acts envisaged in the ETIAS Regulation.  \n1 OJ L 295, 21.11.2018, p. 39.  \n2 Regulation (EU) 2018/1240 of the European Parliament and of the Council of 12 September 2018 establishing a European Travel Information and Authorisation System (ETIAS) and amending Regulations (EU) No 1077/2011, (EU) No 515/2014, (EU) 2016/399, (EU) 2016/1624 and (EU) 2017/2226 (OJ L 236, 19.9.2018, p. 1) .  \n3 EDPS Opinion 3/2017 on the Proposal for a European Travel Information and Authorisation System (ETIAS), issued on 6 March 2017.  \n5. The present formal comments of the EDPS are issued in response to a consultation by the European Commission of 7 July 2022, pursuant to Article 42(1) of Regulation 2018/17254 (‘EUDPR’) . In this regard, the EDPS welcomes the reference to this consultation in Recital 11 of the Proposal.  \n6. These formal comments do not preclude any additional comments by the EDPS in the future, in particular if further issues are identified or new information becomes available, for example as a result of the adoption of other related implementing or delegated acts5.  \n7. Furthermore, these formal comments are without prejudice to any future action that may be taken by the EDPS in the exercise of his powers pursuant to Article 58 of the EUDPR and are limited to the provisions of the draft Proposal that are relevant from a data protection perspective.  \n2. Comments  \n2.1. Time periods in relation to previous criminal convictions  \n8. Pursuant to Article 17(4)(a) of the ETIAS Regulation, as part of the application form for travel authorisation, the applicant must provide information about possible previous criminal convictions. To this end, the applicant must reply “whether he or she has been convicted of any criminal offence listed in the Annex over the previous  \n10 years and in the case of terrorist offences, over the previous 20 years, and if so when and in which country”(emphasis added) .  \n9. The EDPS notes, however, that in Article 2(2) of the draft Delegated Decision, the time periods in relation to a possible previous criminal convictions are significantly extended - 15 years for criminal offence listed in the Annex and 25 years for a terrorist offe","cbCaidzKsg9UO1Y2","https://ap.wps.com/l/cbCaidzKsg9UO1Y2","pdf",1109647,"English","# Introduction and background\n## Time periods in relation to previous criminal convictions\n## Personal data of family members and friends","[{\"question\":\"What is the purpose of the draft delegated decision discussed in the document?\",\"answer\":\"It specifies the content and format of questions for the ETIAS application form and lays down related additional sets of answers and questions.\"},{\"question\":\"How does the EDPS assess the proposed time periods for previous criminal convictions?\",\"answer\":\"The EDPS notes that the draft extends the time periods beyond those in the ETIAS basic act and considers this a contradiction with the delegation limits, urging alignment with the basic act.\"},{\"question\":\"Does the EDPS limit its comments to specific issues?\",\"answer\":\"Yes. The formal comments focus on provisions relevant from a data protection perspective and do not prevent additional future comments if new issues arise.\"}]","EDPS Formal comments on additional set of predetermined questions - ETIAS | PDF",1789822223]