HUMAN RIGHTS AND DEMOCRACY NETWORK

Pro Bono For Data Compliance

Pro Publico connected a Brussels-based human rights and democracy network with Covington & Burling to deliver pro bono GDPR compliance assistance.

GDPR and Pan-European NGO Networks

EU data protection rules (GDPR) pose unique challenges, especially for unregistered networks operating across borders. Decisions around contact data – whether public or private – must be made carefully to avoid compliance risks.

Informal network for human rights and democracy

The applicant was an informal coalition of 65 civil society organizations advocating for human rights and democratic principles across Europe. Although the network itself is lacking any formal registration, the organisations making it up are very active – routinely briefing EU institutions and co-organizing the annual EU NGO Forum on Human Rights. Their common goal behind such a network is to ensure human rights remain central to the EU’s internal and external policies.

Managing Contact Data Under GDPR

The network engaged a dedicated consultant to build an EU contacts list including both public figures (e.g. MEPs) and non-public officials (e.g. Commission staff) but soon the main question became if they could legally retain and update non-public contact data across countries without a formal legal entity? They sought clarity on GDPR scope, retention limits, legitimate interest assessments, internal policies and responsible-designation procedures.

Introducing the GDPR experts at Covington & Burling

Covington & Burling is renowned for its expertise in EU regulatory law and data privacy. Following Pro Publico’s introduction, pro bono lawyer Staś Kuźmierkiewicz coordinated a structured support with top practitioners Kristof Van Quathem, Anna Sophia Oberschelp de Meneses and Alix Bertrand. 

Tailored GDPR Advice

Covington’s team brought high-caliber, strategic pro bono support to the table:

  • Researching GDPR applicability for unregistered, continent-spanning networks.
  • Differentiating rules on public vs non-public data.
  • Clarifying permissible retention periods tied to official posting.
  • Advising on internal compliance measures – codes of conduct, access-designated roles and documentation.
  • Drafting a template legitimate interest assessment to support ongoing contact data processing. 

Covington also offered to train the network’s dedicated team on these tools, ensuring real-world application and compliance know-how.

Pro Bono Impact and Strategic Decision-Making

Armed with Covington’s deliverables, the network’s management held an informed AGM discussion. Their executive director confirmed:

“The legal assistance generously provided was critical to us as a network navigating the complexities of GDPR and provided us a solid legal basis for a discussion at our AGM where an informed decision could be made.  Due to the legal advice, we decided as the network is set up now, it is too risky and difficult to maintain a contacts database. However, we agreed to look at the matter again if the situation with the GDPR changes.”

This outcome shows the true value of pro bono: enabling organizations to decide with confidence – even if the answer is to pause.

Meanwhile the lawyers at Covington said:

“We commend HRDN’s prudent decision to pause the creation of a common contacts database, demonstrating a serious and thoughtful approach to GDPR compliance; this decision highlights the importance of balancing operational goals with privacy risks and legal obligations. While the project is paused for now to find a compliant path forward, we are always happy to brainstorm on practical, GDPR-compliant ways to achieve objectives while respecting data protection principles.”

Connect, Reflect, Repeat

Based on this, the network may revisit its contacts strategy as GDPR evolves. In the meantime, its management will integrate Covington’s materials into their data governance discussions across member organizations.

If your civil society initiative needs expert legal or public affairs support, we’d love to help. Submit your case to Pro Publico or contact us for a confidential conversation.

👉 Submit your case via our intake form

📬 Subscribe to our newsletter

🔍 Explore more impact stories

Thanks to  @StaśKuźmierkiewicz, @DianeValat, @KristofVanQuathem, @Anna SophiaOberschelpdeMeneses, @CovingtonBurling, @Francesco Zatelli @ProPublico

#ProBonoGDPR #CivilSociety #EUCompliance #DataProtection #ProPublico