Public service

Education Implementation Service

DUO makes every effort to prevent payment arrears from becoming time-barred. For debtors whose arrears are about to become time-barred and for whom no residential address is known, DUO may issue a public notice. Public notification means that DUO publishes the debtor’s name and outstanding debt in the Government Gazette. An algorithm is used to determine who is eligible for this. 

Last change on 23rd of June 2026, at 13:10 (CET) | Publication Standard 1.0

• Publication category: Impactful algorithms
• Impact assessment: DPIA, IAMA
• Status: In use

General information

Theme

Education and Science

Begin date

2020-04

Contact information

[e-mail]

Link to publication website

https://duo.nl/particulier/betalingsachterstand/betalingsachterstand-in-het-buitenland.jsp

Responsible use

Goal and impact

The algorithm enables DUO to efficiently select debtors for public service of process. The algorithm speeds up administrative processing by staff. It identifies which debtors have the greatest financial impact on DUO and the State as a whole. Public service of process is a means of preventing claims from becoming time-barred and ensuring that DUO does not have to write off the claim if the debtor’s address is unknown to DUO and DUO is therefore unable to send a reminder.

The algorithm selects debtors whose claims are at risk of becoming time-barred. The staff member then manually determines whether public service of process is an appropriate measure for a particular debtor. If this is the case, DUO publishes a notice in the Government Gazette.

Considerations

By identifying debtors whose claims are at risk of becoming time-barred, the algorithm assists staff in assessing whether public service of process is an appropriate measure for an individual debtor. DUO recognises that public service of process is a measure of last resort that should only be used if there are no other ways of contacting the debtor and/or securing payment of the arrears. The use of the algorithm is justified because public service of process is only carried out in the case of debtors whose claims are at risk of becoming time-barred and for whom DUO has no known residential address. For this specific group, there is no less intrusive alternative for obtaining legal certainty.

Human intervention

The algorithm’s decision-making rules were drawn up by DUO staff, and DUO staff use the algorithm regularly. In this way, DUO continuously evaluates the results and can therefore adjust the algorithm as necessary. The algorithm produces a shortlist; the decision as to whether or not to serve the notice publicly rests with DUO staff.

Risk management

This algorithm does not make automated decisions and cannot independently arrange for a publication in the Government Gazette. The decision as to whether or not DUO opts for public service of process in the case of a debtor rests entirely with the staff member. In addition, DUO applies the ‘four-eyes principle’ (at least two people must be involved in the decision) before it actually proceeds with public service of process.

The selection of debtors whose claims are at risk of becoming time-barred takes place on a monthly basis. This ensures that the selection remains up to date and that the period between selection and public service is as short as possible. As soon as DUO has an up-to-date residential address for the debtor and/or the debtor has paid the arrears, DUO removes the debtor from the selection.

Legal basis

Public service of process is permitted under the law. This is laid down in Article 54 of the Code of Civil Procedure and in Chapters 6 and 10a of the Student Finance Act 2000. The processing is carried out because DUO performs a task in the public interest, as referred to in Article 6(1)(e) of the General Data Protection Regulation.

Links to legal bases

• Code of Civil Procedure: https://wetten.overheid.nl/BWBR0001827/2025-01-01?g=2025-01-01&z=2026-01-14
• Student Finance Act 2000: https://wetten.overheid.nl/BWBR0011453/2025-01-01#Hoofdstuk6
• Student Finance Act 2000: https://wetten.overheid.nl/BWBR0011453/2025-01-01#Hoofdstuk10a

Elaboration on impact assessments

In the IAMA, the various fundamental rights have been weighed up against one another, including any potential positive and negative effects. This assessment shows that the use of the algorithm is balanced and that its deployment is justified.

Impact assessment

• Data Protection Impact Assessment (DPIA)
• Human Rights and Algorithms Impact Assessment (IAMA)

Operations

Data

The algorithm uses the following details of the debtor:

1. Residential address
2. Payment arrears (is there a risk of the debt becoming time-barred?).

In addition, the DUO staff member will examine supplementary internal data relating to a debtor, such as any income or whether they are currently undergoing treatment. Based on this, a staff member may decide whether or not to proceed with public service of process.

Technical design

This is a rule-based algorithm that selects DUO debtors whose claims are at risk of becoming time-barred within a certain period. A rule-based algorithm means that it operates according to fixed rules that have been established in advance. The algorithm follows these rules step by step and does not learn independently.