Registraties gekoppeld op persoonsnummer
Gegevens die voor de ene wettelijke taak zijn verzameld, worden op het persoonsnummer gekoppeld aan die van een andere instantie.
- Familie
- Keten
- Status
- actief
- Geldt voor
- api, web, desktop
Wat er gebeurt
Two public bodies each hold records for their own statutory purpose. The statutory personal number makes joining them trivial, so a file, a query facility or a shared environment comes into being in which records from both sit next to each other about the same person. The combination answers questions neither register was created for. The person sees only the outcome: a check, a selection, a decision that draws on information they gave somewhere else.
Waarom het ertoe doet
Each register was justified separately and the combination was justified nowhere. A person cannot see which body drew on which source, cannot correct a record at the body that used it, and cannot avoid the number, because it is assigned to them. The combined set then becomes the reason to keep data longer, share it further and select on it.
Veelvoorkomende oorzaken
- a sharing arrangement made between bodies without a provision naming the combination
- a joint environment for detection or enforcement, fed from several registers
- one supplier delivering the same platform to both bodies, with the join as a feature
- a provision that permits the delivery of one register, read as covering the combination
Dit is het níet
A statutory number reaching a party with no statutory task is Statutory identification number to a third party, where the recipient should not hold it at all. Here both bodies may hold the number, and the fault is the joining of records collected for different purposes. Two commercial parties matching identifiers is Identifier synchronisation between parties.
Hoe je het vaststelt
Indicator
An access request to one body returns fields that only the other body collects, or the body's own processing register names a source it does not collect itself. Both are documents the body publishes or must supply, and the comparison is a set difference on the fields.
Methode
document-comparison
Kwaliteit van de detectie
80 van 100
De grenzen van deze bevinding
Wat dit patroon zou weerleggen
- A provision names the combination itself, with its purpose and its retention.met de hand te toetsende bevinding vervaltThe discussion then moves to whether the practice stays inside that provision, which is a different and more tractable question.
- The receiving body collected the field itself, from the person.met de hand te toetsende bevinding vervalt
- The exchange is a single answer to a single question, with nothing retained afterwards.met de hand te toetsende bevinding wordt zwakker
- What was returned is a derived value, and the underlying record stayed with the body that holds it.met de hand te toetsende bevinding wordt zwakker
Wat dit patroon níet vaststelt
- harm; the catalogue standardises a finding so it can be referred to, it does not weigh it
- severity; there is no score here, by design. Weighing belongs to whoever applies the entry to a concrete case
- unlawfulness; that is for a supervisory authority or a court
- intent; a fault is usually a build decision, not a plan
- absence: not finding it in one capture is not evidence that it is not there
Reproduceren
- manual
METHOD.mdno dedicated reproduction exists yet; follow the general method and the indicator above
Juridisch kader
Bepalingen
Veelgehoorde tegenwerpingen
Both bodies are allowed to use the number.
For their own task, yes. The number is what makes the join cheap; it is not what makes it permitted. The provision has to name the combination.
It is all one government.
Not in law. Each body has its own task and its own basis, and that separation is the reason a person can give information to one without giving it to all.
We only exchange what is necessary.
Then the exchange answers a question and retains nothing. A stored combination is a different thing, and the two can be told apart by asking what is kept.
The person can request access, so it is transparent.
Access is a right, not a justification. That the combination becomes visible when someone asks does not establish that it was permitted.
Geldt wanneer
to-processing