In his letter sent to Ms Kori Udoviciki, Deputy Prime Minister and Minister of Public Administration and Local Self-Government, and Mr. Aleksandar Vulin, Minister of Labour, Employment, Veteran and Social Affairs, Commissioners for Information of Public Importance and Personal Data Protection Rodoljub Sabic emphasized it was necessary to stop as soon as possible further processing of children's data the two Ministries ordered to be performed by city and municipal administrations by their joint letter of 21 October 2014.
In the said letter, the two Ministries demanded of city and municipal administrations to request from primary schools in their territories data on children (name and surname, unique personal identification number, school, class) who have more than 30 absences without excuse and to forward such data to child protection services in their city or municipality and informed them they would receive further instructions on 3 November.
Several city municipalities contacted the Commissioner immediately after they received this letter, asking him to provide his opinion on admissibility, basis and purpose of such processing of children's personal data.
The Commissioner asked both Ministries to state the legal basis for such data processing, i.e. for instructions of the Ministries sent to municipal administrations, reminding that the main principles of personal data processing, which are also the requirements for admissibility of data processing, are lawfulness, processing for intended purpose, proportionality, data safety and accuracy and timeliness.
The Commissioner also emphasized it was necessary to stop further processing as soon as possible until all dilemmas regarding the manner of children's data processing described above were eliminated and to inform all authorities that were ordered to perform such processing about this in order to prevent adverse consequences and to reduce the risk for the rights of underage persons.