Recommendations
Modification of the provision which provides: if data is given to the Ministry of Labour and Social Policy, the Employment Agency of the Republic of Macedonia and the Health Insurance Fund, for the purpose of their operation on their responsibilities and in accordance with the regulations for protection personal data, only if the bank signs a memorandum of cooperation with these institutions, which will regulate the availability of the data.
Foremost, the access activity is controversial, and then the grounds that allow it.
The envisaged signing of the Memorandum of cooperation with institutions in order to obtain data is controversial because the Memorandum does not have the legal power to allow this to happen, it is not a document based on which those most affected – the citizens can exercise their rights or file complaints. This puts into question the seriousness of the banks, particularly because of the fact that banking secrecy is no longer a secret, but with an exception, the secret is revealed to the institutions.