Area: .nan
Competent authority: FURS, MDDSZ, MF, MJU, MZ, ZPIZ, ZRSZ, ZZZS
EZU URL: .nan
Initiative ID: 1096
Initiative accepted and completed: .nan
Initiative classified in EZU: .nan
Initiative forwarded in response: '2021-01-08'
Initiative published: '2021-01-08'
Initiative submitted: '2021-01-08'
Response from the competent authority: "Reply from the Ministry of Public Administration\
  \ (MoPA):Thank you for your initiative and we fully support it. We are also committed\
  \ to making electronic services as interoperable as possible, i.e. easily connected,\
  \ compatible and interchangeable. This is, of course, conditional on the consolidation\
  \ and unification of the basic registers and records kept by the State. These concepts\
  \ are pursued by all public authorities in the development of new information systems.\
  \ However, we already have many existing information systems in production, which\
  \ need time and resources to be upgraded in the direction of interoperability and\
  \ interchangeability. However, all authorities are striving to develop solutions\
  \ in the direction of a proactive state, taking into account the principles that\
  \ we have also set out in the Guidelines for the development of IT solutions:- Digital\
  \ as a rule:The development of services must be in the direction of electronic services,\
  \ which does not mean that users cannot also access and use them in the traditional\
  \ way in physical form. Electronic services must be provided through a variety of\
  \ modern (digital) channels, taking into account the legality of the back-end processes\
  \ (integrations) and the level of technological capability of the back-end systems.\
  \  Before digitising a service, the service or the process of providing it should\
  \ be carefully examined and made as efficient and user-friendly as possible (for\
  \ example, eliminating unnecessary administrative procedures or the requirement\
  \ for unnecessary evidence and data).- User at the heart of the service:The users\
  \ of e-services and their needs should be one of the main guiding principles in\
  \ the development of these services. The design of the e-service itself must be\
  \ driven by the needs of the users, and the user experience must be monitored throughout\
  \ the use of the e-service. There is a need to be even more responsive to citizens'\
  \ needs and even more flexible in the way it operates. This experience must become\
  \ one of the guiding principles for continuous improvement of e-services. At all\
  \ stages of service design, users must be actively involved in order to identify\
  \ their real needs. Possible methods include surveys, focus groups, stakeholder\
  \ consultations and meetings (physical, remote or by correspondence), design-thinking\
  \ methods, the use of social networks, etc. One of the possible ways is to prototype\
  \ the e-service, testing the user experience on a suitable number and profile of\
  \ users, followed by improvements based on user feedback. Once the e-service is\
  \ in use, it is necessary to monitor any problems users may have, proactively collect\
  \ their feedback on their satisfaction with the e-service and act accordingly.-\
  \ As a rule, \"just once\":All current strategic documents for the development of\
  \ e-business in the public sector and EU legislation (notably the EU Regulation\
  \ on the establishment of a single digital portal to provide access to information,\
  \ to procedures and to help and assistance and problem-solving services) provide\
  \ for a \"one time only\" approach to e-business development in the public sector.If\
  \ the State has certain information about someone, it should not ask for it again\
  \ from a party when it is needed, for example, to provide an e-service; it should\
  \ obtain it itself ex officio. Solutions have been developed some years ago to perform\
  \ electronic data queries (Tray, IO-module, Asynchronous module) and can be used\
  \ in various e-services in the sense of retrieving data on a \"one time only\" basis,\
  \ in compliance with the applicable rules and standards for the protection of personal\
  \ data.- Reusable as a rule:When developing applications, the aim should be to use\
  \ data and services that are already available, or to consider the potential need\
  \ for the resulting data or services to be usable for other solutions/services.\
  \ When developing solutions that allow reusability, it should be taken into account\
  \ that they can be transferred to another country, another technological environment,\
  \ and that the solutions can be adapted to different business processes and a different\
  \ legal environment.- Interoperable as a rule:The development of IT solutions should\
  \ take into account the interoperability of the solutions at different levels, such\
  \ as legal, organisational, IT and technical. The level of interoperability that\
  \ the client wishes to achieve should be specified in the contract specification.\
  \ The contracting authority must clearly define which legal bases the new system\
  \ must respect and which organisational bases it must transpose. Information interoperability\
  \ shall be achieved primarily on the basis of the single record principle and through\
  \ the consistent use of data dictionary tools.- Privacy by design:In order to ensure\
  \ trust in public administration e-business services, the privacy of citizens must\
  \ be respected in accordance with domestic and European Union legislation governing\
  \ the protection of personal data, while at the same time the business secrets of\
  \ commercial entities must also be protected. This principle should be taken into\
  \ account as early as possible, if possible, in the modelling of the solutions themselves.\
  \ It is very important that all those involved in the lifecycle of an information\
  \ system are aware of what data is being processed in the system and adapt accordingly.-\
  \ Open as a rule:Efforts should be made to open up data and services, allowing third\
  \ parties to create new services that emphasise collaborative services.- Transparent:Greater\
  \ transparency, openness, inclusiveness and participation in public administration\
  \ processes contribute to improving trust and reliability.- Inclusive as a rule:When\
  \ designing services, efforts should be made to exclude as far as possible those\
  \ groups of users who are unable to use the internet or who use it in an adapted\
  \ way (for example people with disabilities).- Cross-border as a rule:The principle\
  \ of the European Union's internal market should be taken into account and, where\
  \ appropriate, it should also be possible to allow users from other Member States\
  \ of the European Union and from other countries to use a particular service, and\
  \ to link up with other public administrations as well. The EIDAS Regulation, the\
  \ SDG Regulation, etc. should be taken into account here.Reply from the Ministry\
  \ of Health:Thank you for your initiative. Please find below a brief explanation.\
  \ When we talk about public records, what is important is whether the individual\
  \ institutions have a legal basis for obtaining data from the various records, or\
  \ whether they can only obtain data from a natural person (citizen, insured person).Therefore,\
  \ if there is no legal basis for obtaining data from the individual records, the\
  \ institution can only obtain data from an individual. Thus, residence addresses,\
  \ email addresses, etc., provided by the insured person on the application form\
  \ in a specific procedure are only valid for that procedure and cannot be communicated\
  \ by one authority to another authority to be used for its own procedure. According\
  \ to the General Administrative Procedure Act, service is deemed to be effected\
  \ at the address given by the person on the application. If, during the course of\
  \ the proceedings, a party or his legal representative or an authorised representative\
  \ appointed by the party changes his domicile, registered office or the address\
  \ given in the application or the authorisation, he must immediately inform the\
  \ authority which is conducting the proceedings. If the person has not taken part\
  \ in the proceedings by the time service is effected, service shall be effected\
  \ on him at the address for service. The permanent, temporary and service address\
  \ of the authorities with a legal basis are obtained from the Central Register of\
  \ Residents, not from some procedure that has been carried out at eGovernment.All\
  \ the databases you mention could be linked together if there was a legal basis\
  \ for doing so and if a decision of the Information Commissioner was obtained for\
  \ the linking. However, it should be stressed that special care is required when\
  \ linking and processing personal data collections and that a certain degree of\
  \ proportionality is required when linking them.Reply from the Ministry of Labour,\
  \ Family, Social Opportunities and Equal Affairs (MLDSZ):In the area of decision-making\
  \ on rights from public funds (e.g. In the area of public benefit entitlements (e.g.\
  \ child allowance, state grant), social work centres already have access to basic\
  \ data on citizens (permanent address, temporary address, address for service, bank\
  \ account, etc.) via the Information System of Social Work Centres (ISCSD2). It\
  \ is also possible to obtain other data on persons and their assets and income from\
  \ 48 official data records of database operators. The Ministry of Labour, Family,\
  \ Social Affairs and Equal Opportunities is also continuously upgrading ISCSD2,\
  \ thus providing administrative relief to clients and social work centres.Reply\
  \ from the Financial Administration of the Republic of Slovenia (FURS):FURS receives\
  \ information on the address for service, which the client registers in the Central\
  \ Register of Population. This information is taken into account by the FURS for\
  \ the purposes of service, unless the client informs the FURS of another address\
  \ for service. With regard to the information on the account opened abroad, we confirm\
  \ that this information is held by FURS. The information may be provided to other\
  \ authorities if they have a legal basis for obtaining this information. FURS enables\
  \ the competent authorities to exchange data electronically, with the set of data\
  \ being determined by the authority which needs the data for decision-making, if\
  \ it has a legal basis for doing so.Reply from the Health Insurance Institution\
  \ of Slovenia (ZZZS):With regard to the petitions concerning the address for service,\
  \ we would like to clarify that, in accordance with the Act on General Administrative\
  \ Procedure, ZZZS serves all administrative documents to the insured persons at\
  \ the address for service. Therefore, if an individual has, in addition to his/her\
  \ permanent residence, also a temporary residence, he/she shall be served at the\
  \ address he/she specified as the address for service when registering his/her residence\
  \ at the administrative unit.With regard to the acquisition of data or the exchange\
  \ of data between official records, we would like to clarify that for the purposes\
  \ of inclusion in the compulsory health insurance, the insured person does not need\
  \ to provide certain evidence, since the data kept in the official records are acquired\
  \ by the ZZZS itself. For example, for the registration of a family member, a child\
  \ who is attending school in Slovenia, ZZZS obtains the information on schooling\
  \ from the official register of participants in education and training or the register\
  \ of higher education. The ZZZS obtains data from these two registers when the child\
  \ reaches the age of 18 and then at the beginning of each new school/college year\
  \ for as long as the child is insured as a family member, but not later than the\
  \ age of 26. ZZZS also verifies the information in the official records of the civil\
  \ registry about the marriage or partnership or the information about the registered\
  \ permanent or temporary residence in Slovenia.Reply from the Disability and Pension\
  \ Insurance Institute (ZPIZ):We would like to clarify at the outset that, although\
  \ the petition is addressed more to the ministries, to which the petition has been\
  \ forwarded, we are nevertheless giving our opinion.There are several possible responses\
  \ to the petition. In principle, administrative authorities or their employees conducting\
  \ administrative proceedings obtain personal and other data from official records\
  \ ex officio, in accordance with the provisions of the Administrative Offences Act.\
  \ A very large number of direct database links have already been established between\
  \ administrative authorities in the Republic of Slovenia for the exchange of data,\
  \ insofar as the permissibility of the link is established by law and the content\
  \ of the records of one authority corresponds to the requirements for the performance\
  \ of the other authority's statutory duties. New links are also being established\
  \ all the time with a view to improving the performance of the authorities. However,\
  \ taking into account the provisions on the protection of personal data in the GDPR\
  \ and the GDPR, any such link must be established by law, taking into account the\
  \ other principles of personal data protection, in particular the proportionality\
  \ of the transfer for the purpose of the use of the data. The possibility to exchange\
  \ data is assessed on a case-by-case basis for each type of data or record, as each\
  \ record has its own legalities and limitations.The address for service is entered\
  \ in the Central Population Register (CRP), and it is up to each individual institution\
  \ to decide whether or not to receive this information and how to use it. In the\
  \ case of multiple registered addresses (permanent, temporary), the address for\
  \ service may be entered in the CRP, but it is not compulsory. Any reservations\
  \ that FURS may require an address to be entered, or that it may not take into account\
  \ the address for service as declared in the CRP, can only be explained by FURS.The\
  \ bank account to which benefits are to be transferred must be communicated by the\
  \ insured person or beneficiary and the Institute has no power under the current\
  \ legislation to obtain this information from FURS. There is also no legal basis\
  \ in the ZPIZ-2, ZMEPIZ-1 or the Tax Procedure Act for the Institute to obtain bank\
  \ account information from the FURS or a bank, as this is a matter of tax or banking\
  \ secrecy and these restrictions are established by law precisely to protect sensitive\
  \ personal data. For more information on the reasons for protecting and not disclosing\
  \ bank account data of persons to other state institutions, please contact the FURS.Since\
  \ 2013, data on formal education in the Republic of Slovenia have been kept by the\
  \ Ministry of Education and Science of the Republic of Slovenia in the eV\u0160\
  \ register for higher education institutions and in the CEUVIZ register for education\
  \ programmes from primary to post-primary level. eV\u0160 data are also kept by\
  \ the Ministry of Education and Science of the Republic of Slovenia. However, these\
  \ records only contain the education of persons enrolled in the programmes since\
  \ the beginning of these records, and there is no national inventory of educational\
  \ attainment in publicly funded programmes before the establishment of these records.\
  \ Nor can the registers in the Republic of Slovenia keep records of the education\
  \ attained abroad by citizens or residents of the Republic of Slovenia. As regards\
  \ the data on educational qualifications obtained, which are kept by individual\
  \ higher education institutions in the Republic of Slovenia, the authority which\
  \ is conducting the procedure and which is required to obtain the data on a person's\
  \ educational qualifications in the course of that procedure cannot know from which\
  \ institution the person obtained his or her qualifications in order to be able\
  \ to address a request to that institution to obtain the data."
Text file: 1096.txt
Title: Linking all national records
URL: https://www.stopbirokraciji.gov.si/pobuda/?st=1096
