Municipalities find it difficult to identify misuse of personal data by their own civil servants. This includes, for example, civil servants who provide information to criminals under pressure. These types of data breaches usually only come to light when the National Criminal Investigation Department or a resident alerts the municipality. Municipalities that do discover the misuse often fail to report such data breaches to the Dutch Autoriteit Persoonsgegevens AP), even though they are required to do so.

This is stated in anexploratory study by the AP. The AP calls on municipalities to prevent, detect, and address data breaches caused by integrity violations, and provides various recommendations to this end. Every year, the AP receives reportsof data breachesfrom approximately 10 to 20 municipalities involving civil servants who have unlawfully accessed personal data. Examples include civil servants who:
Monique Verdier, vice-chair of the AP: 'Such privacy violations can have far-reaching consequences. It is important that municipalities improve their ability to prevent, detect, and address these types of data breaches. Municipalities use and store a lot of sensitive information about their residents. People must be able to trust that this information will remain confidential. If data is shared with criminals, it can even pose serious security risks to people. For example, Openbaar Ministerie year the Openbaar Ministerie linked dozens of explosions and at least two attempted murders and homicides to a corrupt civil servant from the municipality of Amsterdam.'
The number of cases of misuse may be significantly higher than the number of reported data breaches. This could be because misuse went undetected or because municipalities often do not recognize integrity incidents as data breaches. There are also misconceptions about what constitutes a data breach and when reporting is mandatory. It is important that such incidents are also reported to the AP, so that the AP can take corrective action if insufficient security measures are taken or intervene if victims are not informed.
Municipalities can take measures to help prevent, detect, and address data breaches. Based on the practical situations it has encountered, the AP provides municipalities with a number of recommendations, such as:
For this investigation, the AP questioned 29 internal privacy supervisors, data protection officers (DPOs), from municipalities about the misuse of data by civil servants. The AP also visited three municipalities and spoke with the National Criminal Investigation Department and the Association of Netherlands Municipalities (VNG). In addition, the AP compared a list of integrity violations at municipalities with its own overview of data breaches at municipalities.
