EU Who is Who Directory — Privacy Notice
How Pauhu® processes personal data from the EU institutional directory
Data controller
Pauhu Ltd
Helsinki, Finland
Email: legal@pauhu.ai
Pauhu Ltd is the data controller for the processing of personal data described in this notice.
Categories of personal data
We process the following categories of personal data from the EU Who is Who directory:
- Names of EU institution officials and staff
- Professional roles and job titles
- Organisational units (directorate-general, department, unit)
- Professional contact information (institutional office address, institutional phone number)
We do not process:
- Private or personal contact details
- Home addresses
- Personal email addresses
- Any data beyond what is published in the official EU Who is Who directory
Purpose of processing
Personal data from the EU Who is Who directory is processed for the following purposes:
| Purpose | Description |
|---|---|
| Institutional knowledge graph | Linking officials to their policy areas, organisational structures, and institutional responsibilities to provide structured, searchable institutional information. |
| NLP entity recognition | Identifying references to officials in legislative documents, press releases, and institutional publications to improve document understanding and cross-referencing. |
| User search | Enabling users to find the right contact at an EU institution by searching for names, roles, or organisational units. |
Legal basis
Article 6(1)(f) GDPR — Legitimate interest
Pauhu has a legitimate interest in providing a searchable directory of publicly available EU institutional contact information. This processing is lawful because:
- The data is already published by the Publications Office of the European Union for the express purpose of public access.
- The processing is limited to professional institutional data — no private or sensitive data is involved.
- The data subjects are public officials acting in their professional capacity within EU institutions.
- The processing does not override the data subjects' rights, as the information is already publicly accessible and relates solely to professional roles.
Data subject rights
Under the GDPR, you have the following rights regarding your personal data:
| Right | Description | How to exercise |
|---|---|---|
| Access (Art. 15) | Request a copy of the personal data we hold about you | Email legal@pauhu.ai |
| Rectification (Art. 16) | Request correction of inaccurate personal data | Email legal@pauhu.ai |
| Erasure (Art. 17) | Request deletion of your personal data | Email legal@pauhu.ai |
| Restriction (Art. 18) | Request that we limit how your data is processed | Email legal@pauhu.ai |
| Objection (Art. 21) | Object to processing based on legitimate interest | Email legal@pauhu.ai |
| Complaint | Lodge a complaint with a supervisory authority | Your national data protection authority or the European Data Protection Supervisor (EDPS) |
We will respond to all data subject requests within 30 days, as required by the GDPR. There is no fee for exercising these rights.
Data retention
We synchronise our copy of the EU Who is Who directory on a weekly basis with the official source. This means:
- New entries in the source directory are added within one week.
- Updated entries in the source directory are reflected within one week.
- Entries removed from the source directory are deleted from our systems within 30 days of their removal from the EU Who is Who source.
If you exercise your right to erasure, your data will be removed within 30 days of your request, regardless of the sync cycle.
International transfers
None. All data from the EU Who is Who directory is stored and processed exclusively within EU jurisdiction. There are no third-country transfers. Our infrastructure operates entirely within the European Union.
Data source
All personal data described in this notice originates from the EU Who is Who directory, published by the Publications Office of the European Union.
Source: https://op.europa.eu/en/web/who-is-who
The EU Who is Who is an electronic directory of the European Union’s institutional organisations. It provides information on the organisational structure of EU institutions, bodies, and agencies, including the names and professional roles of officials.
Contact
For questions about this privacy notice or the processing of your personal data, contact:
Pauhu Ltd — Legal
Email: legal@pauhu.ai
Last updated: 3 March 2026