According to this law, payment instruments and their content and form, other than the form of payment instruments contained in the transfer media, are being provided by the Minister of Finance. With this formulation, the content of the payment instruments are still to be determined by a Rulebook which is not in accordance with the principles of protection of personal data. Additionally, the practice shows that in payments from individuals, the payment instrument contains the PIN without legal basis. Regulation is needed for the processing of this personal data for the stated purpose.
It is necessary to define the keeping time of the gathered personal data.
It is necessary to define the ways for protection of personal data.