How do we notify between public administrations?
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- Processing between administrations
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Since October 2, 2016, Public Administrations have had the duty to interact with each other and with their bodies, public bodies and linked or dependent entities through electronic means that ensure the interoperability and security of the systems. At the same time, these systems must guarantee the protection of personal data and must preferably facilitate the joint provision of services to the interested parties (art. 3.2 of Law 40/2015, of 1 October, on the Legal Regime of the Public Sector - LRJSP).
Inter-administrative relations, regulated by the LRJSP, can be articulated through communications or administrative notifications. Communications between Administrations are simple submissions of information, while notifications are the formal procedure that supports a material right that is to avoid suffering helplessness.
With regard to inter-administrative communications between the Catalan Public Administrations, these must be articulated through the Extranet of the Catalan Public Administrations (EACAT), as already provided for the scope of the Generalitat de Catalunya. art. 11.3 of Decree 56/2009, of 7 April, for the promotion and development of electronic media in the Administration of the Generalitat. When the recipient of these communications is a non-Catalan public administration, this communication will also be made through EACAT, with the procedure "Exchange of records" enabled for this purpose.
However, in the field of inter-administrative notifications in which the recipient of the notification does not act as an invested administration of the prerogatives of a public administration, that is, it does not act on an equal basis , the AOC Consortium as an interoperability node recognized by Law 29/2010 and its By-laws, has so far offered two technological tools available to all Catalan Public Administrations: EACAT (submission) and e-NOTUM.
The fact that each Administration can freely choose the most suitable tool for practicing notifications between Catalan Administrations, has, however, highlighted difficulties in the internal management of entities.
With the aim of improving and facilitating inter-administrative relations in the field of Catalonia, the Digital Transformation Commission (CTD), meeting within the framework of the National Compact for the Digital Society, in which representatives of the Generalitat de Catalunya, the four Catalan Provincial Councils, the Localret Consortium and the AOC, agreed on June 22, recommend and promote actions for notifications between Catalan public administrations to be made through the EACAT platform.
Although EACAT will become the only notification tool among Catalan Public Administrations, the CTD is aware that some Catalan Administrations are currently using e-NOTUM to notify other Administrations. For this reason, with the desire that the change of platforms (from e-NOTUM to EACAT) does not entail internal organizational grievances, the use of e-NOTUM among short-term administrations will not be restricted.
In any case, e-NOTUM will inform the Administrations that want to notify through this technological tool, that a notification is being practiced between Administrations and that the technological tool recommended for these purposes for all the Catalan Administrations is the 'EACAT. In parallel, improvements will be implemented in EACAT that provide greater evidence.