Sanctions

Social Insurance Bank

An algorithm that follows rules to automatically implement legislation for penalties in Child Benefit, AOW, ANW, AIO and remigration as much as possible.

Last change on 28th of October 2024, at 10:36 (CET) | Publication Standard 1.0

• Publication category: Other algorithms
• Impact assessment: DPIA
• Status: In use

General information

Theme

Social Security

Begin date

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Contact information

[e-mail]

Link to publication website

https://www.svb.nl/nl/aow/rechten-en-plichten/boeten-en-maatregelen

Link to source registration

https://www.svb.nl/nl/over-de-svb/hoe-werken-we/algoritmes-sancties

Responsible use

Goal and impact

Algorithms help with difficult decisions where many things matter. As a result, we make fewer mistakes. The system treats everyone in the same situation the same way. A fine often affects you financially. In addition, a fine also has emotional consequences, sometimes more than repaying money. A fine also affects how you have to repay. Debts are common.

Considerations

This is an algorithm that follows rules to automatically implement the legislation for penalties for Child Benefit, AOW, ANW, AIO and remigration as much as possible. The law determines what data we are allowed to use.

Human intervention

If the algorithm cannot automatically process an application for Child Benefit, AOW, ANW, AIO and remigration, the process stops and employees take over the file. We call this customisation. This only works by working with standards, processes and protocols. Usually, citizens automatically get what they are entitled to. But sometimes there are special situations where the standard is not enough. For instance, when citizens or society are unintentionally disadvantaged when implementing laws and regulations. We call this professional bellyaching. As a public service provider, society expects us to apply the human touch. This means that our services must match what citizens need and what they are entitled to. We take into account citizens' individual circumstances and the intention of the law. Sometimes customisation is necessary because a process does not fit the citizen's specific situation. Improving service delivery is a task for the entire government. We work together to provide a complete response to social developments and citizens' needs.

Risk management

The sanctioning process is one of SVB's core processes. The entire organisation is set up accordingly. We recognise standard three-lines-of-defence (3LoD model). The first line is supported by various tools in quality thinking and acting and continuity risk management. The second line consists of departments such as Operational control, Risk management, Quality Assurance and Information Security, which perform and report on quality and performance controls. The third line consists of the audit serves that perform scheduled and unscheduled audits.

Legal basis

The penalty task is laid down in the AOW, ANW, AIO legislation and Remigration legislation

Elaboration on impact assessments

For all sub-processes and deliverable information products within this domain, DPIAs are mandatory since the introduction of the AVG, in which purpose limitation and proportionality are established. So there are multiple DPIAs per domain.

Impact assessment

Data Protection Impact Assessment (DPIA)

Operations

Data

Our main sources are your data in our systems.

Technical design

Decision tree (rule-based). In your pension, benefit or child benefit, we may give a sanction in some cases. A sanction is a fine or measure. We may give a sanction if, for example, you fail to communicate a change. A decision tool helps our staff assess whether we need to impose a penalty or measure. And how high the fine is or how long the measure lasts. Here, we look at: the amount you overpaid, how long you overpaid, the date the report came in, the date the report should have come in.