Centre for Civic Education (CCE) commends the decision of Ministry of Education to seek the opinion of Agency for the Protection of Personal data and Free access to information during the creation of Proposal of Questionnaire for parents within the procedure of enrolment of children to first grade of primary school, in terms of their harmonisation with the provisions of Law on Protection of Personal Data. By doing so, Ministry of Education acknowledged, but also corrected, the mistake of previous management which designed the questionnaire that encroached right into the privacy of citizens and posed a potential mean of party misuse.
New questionnaire was improved compared to the previous, based on which CCE made a substantiated reaction and launched the Initiative for the monitoring over the compilation and dissemination of Questionnaire on basic information of pupils at the Ministry of Education and Primary schools „Štampar Makarije“ and „Radojica Perović”.
We regrettably note the limitations of Agency for the Protection of Personal information, which did not have the professional courage to unambiguously note the violation of Law on the Protection of Personal Data in the case of previous questionnaire. It was hard to establish a clear opinion of Agency based on the extensive Record which CCE received from the Agency for the submitted Initiative, as well as for months-long communication between CCE and Agency. Nonetheless, by approving the new version of questionnaire, Agency also indirectly acknowledged flaws of the previous one, even though it unnecessarily jeopardised its credibility with the manner of addressing this issue.
The amendments that were made in new questionnaire are in line with the CCE recommendations compared to the previous version of questionnaire. Hence, new version of Questionnaire omitted the questions regarding the health condition of members of family, parents’ place of birth, and it also incorporated the provision based on which parents are not obliged to respond to questions. These amendments, along with a clear confirmation of Agency that the questionnaire is legal, prove the CCE was right when it described the content and dissemination of controversial questionnaires as illegal and as a dangerous attempt of unwarranted intrusion to personal data of pupils and their parents.
CCE urges the Ministry of Education to keep a close eye on the manner in which these questionnaires will later be stored in schools, in order to avoid any chance for particular interpretations and use of these data.
Mira Popović, programme associate