The Commissioner for Information of Public Importance and Personal Data Protection on the occasion of several citizen complaints concerning the processing of personal data of pupils and other persons in the process of allocation of free textbooks, performed supervision over the implementation of the Law on Personal Data Protection in the Ministry of Education, Science and Technological Development.

The performed supervision showed that the Ministry itself does not collect or process personal data, and that the Ministry on this project is not being submitted documents containing personal data but only depersonalized summary, statistical data. But, it was also established during the supervision that primary schools (about 1200) collect and process the personal data using the form which they provided to parents with the request to fill it out, the form titled "Free textbooks Project - Application Form", submitted to primary schools by the Ministry. Filling out the form involves the collection of certain personal data whose processing, by the type and manner, with respect to the purpose and basis, is not in accordance with the Law on Personal Data Protection. This primarily relates to obtaining photocopies of certain documents. For example, the purpose of "establishing identity" does not involve the collection and retention of photocopies of ID cards. Also, by obtaining photocopies of health cards, data (including personal insurant number -"LBO") maintained in the registry of RFHI, and this processing is allowed only for the purpose of health insurance. The same applies to the provision of "medical documentation" of the family member's illness.

The Commissioner pointed out in a letter addressed to the Minister of Education, Science and Technological Development that it is necessary that the Ministry informs, as soon as possible, all primary schools to which the present form was already submitted to immediately suspend the further collection of data whose processing is not in accordance with law.