The Commissioner for Information of Public Importance and Personal Data Protection invites all entities which retain or make copies of citizens' identity documents when citizens enter into their official buildings to stop such practice.

The citizens increasingly address the Commissioner because they are required to leave their identity cards with security officers when they enter many official buildings, both governmental and others. Many citizens are with a reason irritated by such requests or are in doubt about their justifiability and lawfulness.

According to Article 3 of the Law on Personal Data Protection (LPDP), retaining of identity documents constitutes personal data processing and fundamental principles for admissibility of every personal data processing according to Article 8 of LPDP are purposefulness (data can be processed only for the specified purpose) and proportionality (data can be processed only to the extent and in the manner sufficient to achieve the purpose of processing).

Although in certain cases it may be justified for officials in public and private sectors to identify persons by having insight into their identity card or possibly by writing down certain persons' data (name, surname, number and type of an identity document, time of and reason for entering and leaving...) for the purpose of preventative or possibly a posteriori protection of property and persons, this certainly does not mean that it is justified to retain or make copies of identity cards because this is obviously unnecessary for achievement of the purpose of processing.

The request to retain identity card ultimately puts citizens in situation where they violate the Law on Personal Identity Card, since Article 21, paragraph 1 of this Law sets out that persons who are required by the law to have identity cards must carry them on their person and provide them on request of officials for the purpose of identification and is directly contrary to Article 47 of the Law on Private Security, which also allows only insight in personal identity cards, but not their retaining.

But what is as important as the "abstract" violation of the Law on Personal Data Protection, the Law on Personal identity Card and the Law on Private Security is the fact that leaving of identity documents (original or copies) in numerous various places without the actual reason and justification significantly increases the risk of abuse of data and documents.