Recommendations
The purpose of processing personal data in accordance with this Act is to provide protection of children from sexual abuse, pedophilia and trafficking of minors through the availability of information for people who live in their environment, and who have been convicted of crimes related to the sexual abuse of minors, pedophiles and trafficking in minors.
The goal is not in accordance with the principles of protection of personal data in terms of availability of information. The practice in countries where such registries are established is the availability of the same to be limited, or, access to the registries be provided to kindergartens, schools, orphanages, boarding schools.
The scope of the data contained in the registry would be appropriate if access is restricted. In this case, when the register is publicly available it is necessary to reduce the volume of personal data (initials, year of birth, street address).
What is against the principles of protection of personal data is that the exemption from the public register is on request of the person. The controller should seize the data after the deadline, regardless of whether the person requested or not.
It is necessary to insert a provision that envisages the application of technical and organizational measures for secrecy and protection of personal data.