Commissioner for Information of Public Importance and Personal Data Protection has estimated the final version of the Action Plan for Chapter 23, at least when it comes to the areas of freedom of access and protection of personal data, to be significantly below the required and expected level.

The Commissioner has stressed, in particular, with regard to the increased media interest, that the planned expenditure for the alleged improvements in the areas in which he operates, have neither been established at his proposal nor reconciled in collaboration with him, he does not support it, and, on the contrary, he considers it largely irrational and unnecessary.

In this regard, the Commissioner, Rodoljub Sabic, has stated the following:

"It is good that in the latest version the idea, which was an option up until yesterday, to spend 320 thousand euros for the ''analysis'' of the improvement of human resources of the Commissioner's Office was dropped. A significantly smaller amount, which is also unnecessary, is now allocated for the ''need'' (8600 euros). It is not immodest, but true to say that that analysis was conducted by the Commissioner a long time ago, and that it is expressed in the Rulebook on job classification in the Commissioner's Office, which was at the time approved by the National Assembly. If this Rulebook were implemented, instead of continuously limiting the institution of the Commissioner, there would be no need to talk about this topic today.

I have the same opinion about the fact that it is planned to spend almost 130 thousand euros for the drafting of the Law on Amendments to the Law on Free Access to Information of Public Importance and the Law on Personal Data Protection. Seriously drafted proposals of both laws were prepared a long time ago; the proposal of the former was prepared in 2012 and of the latter last year. If it was considered that something in them should be amended, improved, or omitted there was more than enough time to do it, with greatly reduced costs.

Finally, the item of 880 thousand euros, which are allegedly planned for ''employment in the Commissioner's Office'' deserves the most attention. It opens up a whole range of questions.

For example, based on which law has the Ministry of Justice engaged in determining of the staffing needs, and moreover, the dynamics of employment in an independent body?

If the funds in the amount of 880 thousand euros have really been planned for the purpose of "employment in the Commissioner's Office" how can it be explained that in the same version of the said Action Plan, in a different part, also with respect to employment in the Commissioner's Office, it is indicated - amount unknown?

Considering the fact that the spending of the greatest, lion's share, which is allocated for ''employment'', of the 880 thousand euros is planned 3-4 years from now, to what extent is such planning really serious? Doesn't it, already at first glance, cause skepticism about reality?

Finally, while we are at reality and multiannual planning, I have to mention the incomprehensible fact that even this version of the Action Plan for Chapter 23 fails to mention the adoption of the Action Plan for Implementation of the Strategy of Personal Data Protection which the Government was supposed to adopt 5 years ago, and without which adoption and implementation it is not realistic to expect any serious progress in this area."