On May 15, the APDCAT presented the report of Audit 1/2018, on the portals of transparency, a comprehensive report to verify compliance with personal data protection legislation, in active advertising on transparency portals.
The report includes a series of general guidelines applicable to any information that needs to be published on the transparency portals. In this regard, remember that from the you local people have to watch out for this weighting between transparency duties and data protection be a reality. Here is a short summary:
Guideline 1: Do not publish personal data if you do not have a legal basis
Guideline 2: Do not disclose more personal data than is necessary for the purpose of transparency (examples: full DNI number together with name and surname, handwritten signatures or DNI in electronic signatures).
Guideline 3: Ensure that the data is correct and up to date.
Guideline 4: Avoid disseminating data beyond the applicable deadline.
Guideline 5: Inform those affected that their data will be published.
Guideline 6: Establish measures to limit the misuse of internet search engines.
It should be noted that the report goes far beyond the general guidelines and also includes a series of specific guidelines for different data sets. For more information you can consult the detail of the report.
From the Network of Transparent Governments we are analyzing in detail the different areas where APDCAT makes recommendations, and we have already begun to incorporate changes to the transparency portals, especially in the automatic items that we make available to you. Specifically:
Staff announcements
We have replaced the current publication of calls for staff to incorporate only those calls from the year of entry into force of Catalan Law 19/2014, of 29 December, on transparency, access to public information and good governance. (LTC).
In this sense, all public calls available on the portals are from January 1, 2015. If subsequently the regulations of the LTC limit the period of publication (currently in progress) we will adapt it.
Results of staff calls
We have replaced the current publication of the results of the calls for staff by incorporating only the calls already resolved. A condition has also been added on the date of publication, specifically the results of the calls are published from 1 January 2015.
Statutes
We have replaced the current publication of the statutes by incorporating only the current statutes.
Regulatory ordinances and regulations
We have replaced the current publication of the regulatory ordinances and regulations incorporating only the current ones.
Tax ordinances
We have replaced the current publication of the tax ordinances by incorporating only the current ones.
Calls for grants and aid
We have replaced the current publication of the results of the calls for grants and aid from local governments, incorporating only the information of the last 5 years, which we will automatically replace.
Other improvements we are making
At the same time, we are working so that in the next version of the portal the information associated with personal data is not indexed automatically and by default to search engines (such as google, bing…), through the implementation of mechanisms that prevent search engines. external internet indexing contents.
Finally remember that the key is the weighting and anonymization at source, whether at the time of making a minutes of the plenary or governing board, a publication of a call for grants and subsidies, or a list of suppliers, contractors and contractors, etc.
From the Network of Transparent Governments we continue to work to improve the portals in their contents, visualization and weighting of personal data wherever we can, with the mission of enhancing transparency and making it closer to the public, but remember that, despite the automation at source that we propose, from the local bodies you have a very important task of reviewing, maintaining and publishing public information on the portals.
