Passport alerts

Education Implementation Service

The algorithm assists DUO in selecting debtors who may be eligible for inclusion in the Passport Alerts Register. A passport alert means that a person of Dutch nationality may have their application for a new passport refused.

Last change on 30th of June 2026, at 13:55 (CET) | Publication Standard 1.0

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

General information

Theme

Education and Science

Begin date

2016-12

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 assists DUO in selecting and prioritising debtors who may be eligible for inclusion in the Passport Alerts Register. This concerns debtors who are Dutch nationals, have arrears of €5,000 or more with DUO, and have no known place of residence or registration in the Kingdom of the Netherlands as far as DUO is aware.

As the number of debtors who may meet these criteria exceeds DUO’s staffing capacity, the algorithm assists in prioritising cases. To do this, the algorithm checks whether the debtor holds a Dutch passport and how long it remains valid (normally ten years).

Considerations

The selection process ensures that debtors are only flagged for passport alerts where this is permitted by law and where it is genuinely necessary. DUO only uses passport alerts if there are no other ways to re-establish contact with the debtor and/or to ensure that they settle the outstanding debt. That is why a thorough human assessment is always part of the selection process.

Human intervention

DUO uses the algorithm solely as a tool to assist with the preparation of its work. The algorithm selects and ranks the files, but does not make any decisions itself.

The selection process is always followed by a human assessment. Before DUO passes the data on to the National Identity Data Service (RvIG) as a recommendation, a member of staff assesses each individual case to determine whether or not DUO should issue a passport alert. Finally, the RvIG carries out a final check to prevent a debtor from being wrongly included in the register.

Risk management

This algorithm does not make automated decisions. Before DUO submits a request for registration, the organisation still applies the ‘four-eyes principle’ (at least two people are involved in the decision). Following registration, a manual review takes place at least every two years to assess whether the passport alert needs to be extended.

Finally, DUO continuously monitors whether the debtor’s circumstances have changed and whether the legal conditions for the passport alert still apply.

Legal basis

Article 22 of the Passport Act sets out which authorities may, in which situations, request that a new passport be refused (i.e. make an entry in the Passport Alert Register). For DUO, paragraph (b) of this article is relevant, namely failure to comply with the obligation to repay loans granted by the government.

Links to legal bases

Passport Act: https://wetten.overheid.nl/BWBR0005212/2024-01-01#HoofdstukIII

Elaboration on impact assessments

Impact assessments have been carried out for this algorithm, in which privacy rights and human rights have been weighed against its positive and negative effects. The conclusion drawn from these assessments is that the use of the algorithm 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. Dutch nationality (yes/no)
2. The country where the debtor lives
3. Amount of payment arrears

Prioritisation of debtors is based on the following data, sourced from the Basic Register of Travel Documents:

1. Possession of a Dutch passport
2. The expiry date of the passport

Technical design

The algorithm is a rule-based algorithm that selects DUO debtors who meet the legal requirements for passport alerts. 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.