Back Privacy Statement - ICG
PROTECTION OF YOUR PERSONAL DATA
This privacy statement provides information about the processing and the protection of your personal data.
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Processing operation: Import of Cultural Goods System (ICG System)
Data Controller: DG Taxation and Customs Union (TAXUD) – Directorate A: Customs – Unit A4: Protection of citizens and enforcement of IPR
Record reference: DPR-EC-22549
Table of Contents
- Introduction
- Why and how do we process your personal data?
- On what legal ground(s) do we process your personal data?
- Which personal data do we collect and further process?
- How long do we keep your personal data?
- How do we protect and safeguard your personal data?
- Who has access to your personal data and to whom is it disclosed?
- What are your rights and how can you exercise them?
- Contact information
- Where to find more detailed information?
1. Introduction
The European Commission (hereafter ‘the Commission’) is committed to protect your personal data and to respect your privacy. The Commission collects and further processes personal data pursuant to Regulation (EU) 2018/1725 of the European Parliament and of the Council of 23 October 2018 on the protection of natural persons with regard to the processing of personal data by the Union institutions, bodies, offices and agencies and on the free movement of such data (repealing Regulation (EC) No 45/2001).
This privacy statement explains the reason for the processing of your personal data, the way we collect, handle and ensure protection of all personal data provided, how that information is used and what rights you have in relation to your personal data. It also specifies the contact details of the responsible Data Controller with whom you may exercise your rights, the Data Protection Officer and the European Data Protection Supervisor.
The information in relation to processing operation under the ICG system undertaken by DG Taxation and Customs Union, Unit A4 Protection of citizens and enforcement of IPR, along with the customs authorities, as well as the partner competent authorities, is presented below.
2. Why and how do we process your personal data?
Purpose of the processing operation:
European Parliament and Council Regulation (EU) 2019/880 on the introduction and the import of cultural goods laid down the requirement, as of 28 June 2025, to have an import licence or to have drawn up an importer statement in order to be able to bring legally into the Union certain categories of cultural goods created or discovered in third countries. The Regulation also provides for the establishment of a centralised electronic system for the import of cultural goods, the so-called ICG system, for the storage and exchange of information between Member States, authorities in charge of implementing the Regulation (cultural and customs authorities) and the accomplishment of formalities by EU importers, namely, applying for import licences to competent authorities in the Member States and drawing up and submitting importer statements to EU customs, in a digital environment.
It is in this context of import licencing/certification formalities that the processing of personal data of EU importers (applicants and declarants) is to take place in the ICG system. Commission Implementing Regulation (EU) 2021/1079 provides further detailed arrangements with regard to the use and function of the ICG system, including the roles and responsibilities of the Commission and the Member States as personal data controllers.
3. On what legal ground(s) do we process your personal data?
We process your personal data because the processing is necessary for the exercise of official authority vested in the Union institution or body according to Regulation (EU) 2019/880 of the European Parliament and of the Council of 17 April 2019 on the introduction and the import of cultural goods and Commission Implementing Regulation (EU) 2021/1079 of 28 June 2021 establishing uniform practical arrangements for the application of Regulation (EU) 2019/880.
4. Which personal data do we collect and further process?
The following categories of personal data are requested in order to sign into the web applications of ICG through ECAS and SAAS (authentication and authorisation systems – EU Login), and consequently processed for the performance of the operations relevant to the performance of official activities:
- first name;
- family name;
- e-mail address;
- phone number;
- postal address;
- Economic Operators Registration and Identification (EORI) number;
In addition, the following personal data are processed:
Economic operator's data that are being collected include the operator's name, address, contact details. Users attached to these operators have to indicate their personal details (name, contact details and where appropriate identification data). When submitting a licence into ICG, the name of the user performing the submission is visible.
Officials from national authorities’ data include the users' personal details (name, contact details). Upon performance of operations within ICG their name and role are visible.
5. How long do we keep your personal data?
The Data Controller only keeps your personal data to fulfil the purpose of collection or further processing.
As per the Article 10 of the Regulation (EU) 2019/880, “the authorities shall store personal data obtained pursuant to Articles 4, 5 and 8 for a period of 20 years from the date on which the data were obtained. Those personal data shall be erased upon the expiry of that period.”
Personal data from the ICG licences issued in ICG shall be stored by ICG for no more than 20 years.
6. How do we protect and safeguard your personal data?
All personal data in electronic format (e-mails, documents, databases, uploaded batches of data, etc.) are stored either on the servers of the European Commission or its contractors. All processing operations are carried out pursuant to the Commission Decision (EU, Euratom) 2017/46 of 10 January 2017 on the security of communication and information systems in the European Commission.
The Commission’s contractors are bound by a specific contractual clause for any processing operations of your data on behalf of the Commission, and by the confidentiality obligations deriving from the transposition of the General Data Protection Regulation in the EU Member States (‘GDPR’ Regulation (EU) 2016/679.]
In order to protect your personal data, the Commission has put in place a number of technical and organisational measures. Technical measures include appropriate actions to address online security, risk of data loss, alteration of data or unauthorised access, taking into consideration the risk presented by the processing and the nature of the personal data being processed. Organisational measures include restricting access to the personal data solely to authorised persons with a legitimate need to know for the purposes of this processing operation.
7. Who has access to your personal data and to whom is it disclosed?
Access to your personal data is provided to the Commission staff responsible for carrying out this processing operation and to authorised staff on a “need to know” basis. Such staff abide by statutory, and when required, additional confidentiality agreements.
The Commission and in particular the Controller cannot be held responsible for the use and processing of the information that may be made by persons who do not belong to the Commission.
The persons in the Commission who have access to all collected personal data and have the possibility to modify them upon request are: the Controller, identified officials in the unit in charge of the ICG, identified officials in the IT sector in charge of the technical assistance to the units.
The recipients of the data can be distinguished as indicated below:
Recipients within the EU organization:
- Commission Officials
- Commission External staff
Outside the EU organisation -1
- EU Member States competent authorities (in order to overview and manage the information, data and relevant documents that are exchanged under their area of responsibility);
- Customs authorities - (access to import licences and importer statements in the ICG system via CSW-CERTEX for import customs controls purposes, Record Reference: DPR-EC-08326);
- Importers – (access to their own personal data).
The controller will transfer your personal data to the following recipients in a third country or to an international organisation in accordance with Regulation (EU) 2018/1725:
- Competent authorities of non-EU countries - in cases where these countries need to be notified about cultural goods entering Northern Ireland (applicable for transfer to the United Kingdom).
1 See glossary.
8. What are your rights and how can you exercise them?
You have specific rights as a ‘data subject’ under Chapter III (Articles 14-25) of Regulation (EU) 2018/1725, in particular the right to access your personal data and to rectify them in case your personal data are inaccurate or incomplete. Where applicable, you have the right to erase your personal data, to restrict the processing of your personal data, to object to the processing, and the right to data portability.
You have the right to object to the processing of your personal data, which is lawfully carried out pursuant to Article 5(1)(a) on grounds relating to your particular situation.
You can exercise your rights by contacting the Data Controller, or in case of conflict the Data Protection Officer. If necessary, you can also address the European Data Protection Supervisor. Their contact information is given under Heading 9 below.
Where you wish to exercise your rights in the context of one or several specific processing operations, please provide their description (i.e. their Record reference(s) as specified under Heading 10 below) in your request.
9. Contact information
- The Data Controller
If you would like to exercise your rights under Regulation (EU) 2018/1725, or if you have comments, questions or concerns, or if you would like to submit a complaint regarding the collection and use of your personal data, please feel free to contact the Data Controller, DG Taxation and Customs Union/ Directorate A – Customs, Unit A4 Protection of citizens and enforcement of IPR, TAXUD-unit-A4@ec.europa.eu
- The Data Protection Officer (DPO) of the Commission
You may contact the Data Protection Officer (DATA-PROTECTION-OFFICER@ec.europa.eu) with regard to issues related to the processing of your personal data under Regulation (EU) 2018/1725.
- The European Data Protection Supervisor (EDPS)
You have the right to have recourse (i.e. you can lodge a complaint) to the European Data Protection Supervisor (edps@edps.europa.eu) if you consider that your rights under Regulation (EU) 2018/1725 have been infringed as a result of the processing of your personal data by the Data Controller.
10. Where to find more detailed information?
The Commission Data Protection Officer (DPO) publishes the register of all processing operations on personal data by the Commission, which have been documented and notified to him. You may access the register via the following link: [en] privacy.statement.icg.paragraph.content.more.information.dpo.register.url.
This specific processing operation has been included in the DPO’s public register with the following Record reference: DPR-EC-22549.
Glossary
| Competent Authorities | Competent Authorities (CAs) are public authorities or bodies dealing with cultural affairs that are designated in each Member State to assess and approve applications for import licences. CAs may also monitor the overall in-flow of goods under importer statements or under special exemption from certification requirements such as for safekeeping, or for exhibitions and other educational purposes. Moreover, Competent Authorities manage the registration in the ICG system of different entities and persons who wish to benefit from such exemptions. |
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| Customs Authorities | National Customs Authorities represent the customs authorities of the Member States, implementing customs and other legislation with respect to the movement of goods across the borders of the Customs Union territory. This includes controls of the required certification that should accompany certain consignments. They interact with the economic operators by receiving and processing the relevant customs declarations. |
| Importers |
EU importers (economic operators or private collectors) create and make accessible to EU customs at the time of import two types of documents that contain their own personal data, based on the reason for import and the type of cultural goods being imported:
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