The birth or identity card number and the census number are not sufficient to provide the necessary level of reliability of the software for checking the data listed in the upcoming census.
This, among other things, he told "Vijesti". Dejan Abazović, Master of Electronics and Telecommunications, former State Secretary in the Ministry of Public Administration (MJU).
Abazović also said that the census was an opportunity to promote new digital services and that the electronic identity card, which contains certificates for digital signature and electronic identity, should have been used.
"The census was a great opportunity to promote new digital services and technological possibilities and thus accelerate the development of the digital society in Montenegro. First of all, we had to use our new ID card, which has both an electronic identity certificate and a qualified electronic signature certificate. In addition, there are other methods and established infrastructure (NS-eID), both for electronic identification and for electronic signature (remote sign), which could be put into operation. Especially for those citizens who do not have a new identity card," he told "Vijesta".
A missed opportunity
In a digital society, as Abazović said, every citizen must have his own digital identity.
"I'm afraid that a great opportunity, which occurs once in ten years, has gone to waste," said Abazović.
According to him, online enumeration does not mean that other manual possibilities of data collection are excluded.
"Regardless of whether they are entered with a pencil on the list or directly typed on the spot on a tablet or laptop. "How much more efficient and rational the census would be in that way, we don't need to mention," he said.
The last census in Montenegro was conducted in 2011, the regular one in 2021 was postponed due to the coronavirus pandemic, and later the topic was a point of contention among politicians.
In 2021, Croatia organized a regular census and then, for the first time in that country, citizens were enabled to register themselves independently, using the census questionnaire in electronic form.
When asked to comment on the fact that the census in Montenegro today will not be organized, at least partially, in such a way that it is possible for citizens to register themselves, online, through a platform created for that purpose, Abazović says that he does not know what the reason is, but he also says if that was possible.
"I know that it was possible to realize it that way, especially taking into account all the legal and accompanying norms that allow it to be done. I emphasize that to the greatest extent it is harmonized with international standards and, most importantly, with EU regulations, before the other eIDAS and GDPR. In addition, our identity card is fully compliant with the EU Regulation on strengthening the security of identity cards of citizens of the Union and residence documents issued to citizens of the Union and their family members who exercise the right to free movement," he said.
The Directorate for Statistics (Monstat) previously told "Vijesta" that the census cannot be organized, even partially, online, because the state does not have a valid address register. Azabović said that even with the traditional census, enumerators will certainly enter what the citizens tell them.
"The address register, before the others, should be 'based' on the register of residence, which is a very important issue for the voter's list as well. If it was a registration list, I would understand this attitude of Monstat. It would certainly be good if it existed for this type of list and that many data would be related to organized and correct addresses. This way, I don't see the difference between what I will tell the enumerator, who will perhaps suggest to me how to write the address correctly, which I can't check anywhere, or what I will enter independently, online, with quality instructions and quality validation of the entered data," Abazović said. .
The census was supposed to be held from November 1 to 15, but the government canceled it Milojko Spajić immediately at the choice of adjournment. According to the latest announcements, it will be held from November 30.
In October, Monstat announced that, after the census, citizens would be allowed to check the census data. Last week, the parliamentary majority proposed changes to the Census Law. In the proposal, it is stated that the software is established for the purpose of verifying data, which relate to issues of national or ethical affiliation, religion, mother tongue, the language a person usually speaks... It also says that the Government will, in order to establish the software, as well as audit code, form a commission...
By-laws, as stated, will be adopted within ten days from the entry into force of the amendments to the law.
Public invitations will slow down software development?
When asked if the state, if software for verification is created, could also create software for entering census data, so that citizens who want to, at least some of them, could register themselves, Abazović says that the creation of that software solution is a more complex requirement .
Speaking about the deadlines for creating a software solution for checking the listed data, he said that for a more concrete answer it is necessary to solve some dilemmas.
"The Law on Amendments to the Law on Census of Population, Households and Dwellings, Articles 26a and 26b, provides for the 'establishment' of software for checking data collected during the census. The creation of the software solution itself can be completed in a relatively short period of time. It is not completely clear to me the foreseen procedure of 'public invitation', except when it comes to cases from Article 2 of the Law on Public Procurement, i.e. in the areas of defense and security or the areas of granting concessions and public-private partnerships", he said and added that the procedure foreseen in this way "certainly requires more time than the preparation itself".
"In addition to the above, a second 'public call' is planned for the selection of an IT company for auditing the software code. In general, the development and implementation of a standard software solution is unnecessarily complicated by bureaucratic procedures. That is the first reason why I cannot say how long the entire procedure of 'establishing' a software solution can last", said Abazović.
As another reason, he cites imprecise deadlines for the completion of the entry, i.e. the beginning of the control of the entered data, as well as the completion of that process.
"I assume that the control cannot be done indefinitely and that it has a specific expiration date. If some procedural action is introduced into the procedure of the business process, then it must be defined when it starts and under what conditions, as well as when it ends," said Abazović.
Possible misuse or compromise of personal data?
He emphasizes the issue of digital identification of citizens who will control their data as important.
"First of all, because of the possible misuse and compromise of personal data. That part of the software solution must be done in accordance with the Law on Electronic Identification and Electronic Signature and especially the accompanying Rulebook on Minimum Technical Standards and accompanying procedures in relation to which the degree of security of the electronic identification system is determined. My view is that in this software solution, at least, a medium level of reliability must be applied, i.e. two-factor identification,” he said.
As he added, certainly a check based on three (or more) data, which was discussed in public, which would include JMBG, ID card number and census number, "is not two-factor identification".
"Although JMBG or LK number is required as a unique identifier of a registered citizen. It can also be a census number, but somewhere it must be uniquely connected to one of the two mentioned numbers. Bearing in mind that the JMBG contains personal data, in my opinion it was much more appropriate to use the new ID, which, in accordance with the Law on Identity Cards, every citizen already has", said the interlocutor of "Vijesti".
Monstat recently told the Raskrinkavanje.me portal that the census slips are not numbered, i.e. they do not have serial numbers, but they did not answer whether the codes (numbers) are listed in the header of the census slip, which refer to the municipality/census circle/apartment/person can be used as a unique identifier for data entry and processing.
Abazović also said that the issue of personal data protection should be more acceptable in the future.
"First of all, the exceptionality of the Law on the Census of Population, Households and Apartments in relation to the Law on the Protection of Personal Data, which defines that statistical data cannot contain identity data. However, the same law defines in Article 6 that "in the case when the purpose of personal data and the method of their processing are prescribed by law, the operator of the collection of personal data is determined by that law". The protection of personal data, in the sense of privacy protection, is one of the basic human rights and is necessary for the proper functioning of any democratic society. In this sense, I think that this issue should be raised in the future and defined in a more acceptable way," he said.
See more:
Download the app and follow the news
FOLLOW US ON
