Centre for Civic Education (CCE), Institute Alternative (IA) and Network for Affirmation of Non-governmental sector (MANS) defined the set of information which every public sector body should post proactively on 15 every days at their websites.
The objective of this precisely focused initiative is to reduce the space for potential misuse of public sector bodies for electoral purposes, which was previously demonstrated through the affair “Recording”, as well as through numerous other cases of misuse which NGO sector and independent media highlighted. Furthermore, this would facilitate the investigation of these misuses for the interested part of the public, but also increase the overall level of transparency of institutions.
Three non-governmental organisations defined more than 90 categories of information which institutions should post regularly on their websites. These information were divided in two groups – general information on finances and work which contain 27 different categories of information and nearly 60 categories of additional information which were defined particularly for every institution which could be used to influence the process of elections or for other related corruption actions.
Information which every institution should proactively post on its website includes: analytical cards with the information on every payment and receipt; travel warrant for country and abroad; every decision and every type of contract on employment or engagement on indefinite or definite period of time; every information on paid severance pay; every relevant information on public procurement; every information on the allocation of all forms of aid to legal and natural persons; every contract on loans, cessions, mortgages, fiduciaries, sponsorships, donations and financial leasing; every international project with the accompanying documentation; every protocol, agreement, contract and memorandum signed with local self-governments, NGOs, commercial subjects and other bodies; plans of work and financial reports; list of officials and employees with the amount of salaries; every financial payment, donation and assistance to media; as well as many other information which can determine the attempt of direct or indirect influence on the free will of citizens to choose.
Hence, the Ministry of Finances and local secretariats dealing with finances should post the excerpts from state or local treasury and analytical cards of budgetary reserve. Additionally, the Ministry of Finances should have to post complete documentation on the write-off or the exemption from tax and customs duties or postponement of their payment; every information on payments on the basis of restitution; every information on state aid; issued guarantees and short-term aid to local self-government units; information on internal redirections of budget, and similar.
Apart from the information posted by the institutions, they defined additional categories of information which must be posted for additional 17 groups or individual institutions, which are of special importance for free and fair elections.
Apart from that, Ministry of Labour and Social Welfare should have to post analytical cards containing the information on the amount and number of users of every form of social aid, as well as the information on type and recipients of social aid; requests and decisions on the allocation of one-off social compensations; contracts for the construction of housing objects for social cases, as well as for the objects of social and health care with the accompanying documentation.
Ministry of Interior should post every information on the award of Montenegrin citizenship with special conditions with the complete accompanying documentation, including the explanations of decisions, while the Ministry of Agriculture should post the information on the allocation of subventions and agricultural loans, information on the provision of aid to municipalities and municipal communities for the construction of water pipes, roads and other, as well as the contracts on loans signed by the Ministry including the IPARD like and Abu Dhabi Fund.
Additional categories of information which should be posted were also defined for the Government of Montenegro, Commission for the allocation of part of budgetary reserve funds, Ministry of Education, Labour Fund, Employment Agency of Montenegro, Investment and Development Fund, Directorate for the development of small and medium-sized enterprises, Directorate of Public Works and Directorate for Traffic, Ministry of Justice, University of Montenegro and state or locally-owned companies.
These requests are not in conflict with the Law on the Protection of Personal Information. In line with the undisputed interest of public to know, it is necessary to publish the information by observing the provisions of this and Law on Free Access to Information. These laws envisage the procedures of adequate manner of protection of personal information which are of significance for privacy, as well as the information marked with a degree of confidentiality, with the disclosure of basic information.
We urge every institution, bodies and other legal entities in the possession of state or local self-governments unit to adopt special bylaws and thus to norm the obligation to proactively post every information which can determine the presence and the extent of influence of public funds and authorisations on the process of elections and related corruption actions.
Also, we urge the institutions to publish the information related to flows of money in a machine-readable format, so that their processing would be possible. Current practice where bodies posted bulky budgetary database in “locked” scanned documents in PDF format, presented the obstacle for any analytical work with data, which is unacceptable in a situation where one tries to prevent misuse of state money for the needs of party interests and election campaigns.
Centre for Civic Education (CCE)
Institute Alternative (IA)
Network for Affirmation of Non-governmental sector (MANS)