On January 28, the annual Dutch Privacy Awards will be presented during the National Privacy Conference organized by ECP and Privacy First. These awards provide a platform for organizations that view privacy as an opportunity to distinguish themselves positively and that demonstrate how to do business and innovate in a privacy-friendly manner.
One of the six nominees is Publiosa. Many (semi-)governmental organizations do not publish their processing register online. And when they do, it is often in a format that is difficult to access or search. With Registervanverwerkingen.nl, Publiosa shows that there is room for improvement. The company is not deterred and remains committed to transparency regarding the processing of personal data.
The jury of the Dutch Privacy Awards has therefore nominated Publiosa for this award. In this article—part of a series introducing the six nominees—we get to know the company.
Registervanverwerkingen.nl is a social initiative by Publiosa that helps government organizations publish their Register of Processing Operations (Rvv) in an accessible, understandable, and searchable manner, free of charge.
We see that when government organizations choose to publish their Rvv, they often do so in a very confusing and inaccessible way. They are often published as Excel or PDF files, but due to the amount of information, users (residents, journalists, and experts) have to resort to all kinds of tricks to make the information readable at all. The organizations themselves are aware of this, as they provide tips such as: "Set your zoom to 300% to make the text readable."
This is impossible to use for people who are digitally illiterate, visually impaired, or who use assistive software. As a result, they are unable to exercise their privacy rights, such as the fundamental right under Article 10 and the other rights under the GDPR.
Employees of this government organization naturally encounter this problem as well, which means that they often lack an overview themselves and the registers contain many errors and/or outdated information.
The initiative therefore solves two structural privacy problems
• citizens do not know exactly what governments do with their data,
• registers are not accessible, not up-to-date, and not user-friendly.
By converting registers into an accessible web version free of charge, transparency is not only made possible but also more readable and accessible to everyone.
The reason lies in an observation that is common to many government organizations: although it is not mandatory to publish a Register of Processing Operations, it is one of the most powerful tools for transparency towards citizens. Yet most registers are difficult to find, difficult to read, and not designed in accordance with accessibility requirements such as WCAG.
In addition, it appears that many registers are years behind and are not up to date. As a result, residents do not have a clear picture of what happens to their data, and the government unintentionally fails to communicate transparently. Because Registervanverwerkingen.nl offers a simple, free, and scalable way to publish registers, it also serves as an incentive to keep the Register of Processing up to date within the organization. After all, it is available online.
The impact is visible on three levels:
The biggest challenge lies not in technology, but in culture and awareness. Many governments do not yet consider publication of the register a priority, because it is not required by law.
We see that transparency is often pursued, but that there are many barriers that make publishing difficult. Keeping a register constantly up to date is an internal process that can be time-consuming. Because it is not made public, it is given low priority and is therefore never updated, which means that no innovation takes place, so it cannot be made public, which means it remains a low priority. It is a vicious circle. Not to mention the fact that publishing is often a long, expensive, and technical process.
By offering an accessible solution, free of charge and without technical requirements, that barrier disappears almost entirely. The initiative shows that governments do want to publish, as long as it is easy and secure to do so.
The plans focus on further growth within the Netherlands and subsequent European expansion.
The main objectives for the coming period are:
In the longer term, the initiative aims to contribute to a government in which publication of the Register of Processing Operations is not exceptional but self-evident. A government in which citizens can see clearly and accessibly what happens to their data. The next step is to focus on all organizations outside the government domain that would benefit from this.
