Profile (CJIB) Undeliverable return (OBR) National Approach to Address Quality (LAA)

National Authority for Identity Data

The OBR profile concerns cases where the Central Judicial Collection Agency (CJIB) has reasonable doubt about the accuracy of address details in the Basic Registration of Persons (BRP). Part of the National Approach to Address Quality (LAA).

Last change on 27th of May 2024, at 12:06 (CET) | Publication Standard 1.0

• Publication category: Impactful algorithms
• Impact assessment: Field not filled in.
• Status: In use

General information

Theme

Organisation and business operations

Begin date

05-2023

Contact information

[e-mail]

Link to publication website

https://www.rvig.nl/landelijke-aanpak-adreskwaliteit-laa

Responsible use

Goal and impact

The purpose of this algorithm is to select potential high-risk addresses based on reasonable doubt and provide them to municipalities for further address searches. Based on these address searches, incorrect address data is corrected so that public bodies can perform their public duties based on accurate information.

Using the algorithm, you can prioritise addresses where there is a greater than 50 per cent chance that something is wrong in the registration and at the same time ensure that you do not visit citizens' doors unnecessarily. There is no automatic decision-making in this algorithm. There is always human intervention by the municipal official and the LAA partnership, which consists of signal providers, RvIG, the VNG and the NVVB.

If an enquiry into registration of persons at the address is going to take place, a home visit to the address is carried out which may involve personal privacy.

Based on its own address investigation, the municipality decides whether the address data in the BRP should be updated. A decision by the municipality can be appealed.

The profile does not use (personal) data that could lead to discrimination and does not select on nationality, place of birth or derivatives thereof.

Considerations

The accuracy of (address) data in the BRP is essential for the functioning of the Dutch government. A government that does not know or does not know how to find its citizens is unable to perform the tasks entrusted to it by its citizens. In many cases, it is a precondition for the correct implementation of legal regulations and for the effectiveness of government policies. For citizens, proper registration is important for their correspondence with the government and for claiming address-related government services.

The algorithm ensures efficient and most effective finding of addresses where there is a high probability of incorrect address registrations. Using the algorithm, you can prioritise addresses where the probability of incorrect registration is greater than 50 per cent while ensuring that you do not unnecessarily visit citizens' doors. If an address meets the algorithm's selection criteria, the address is shared with a municipality. Following the signal, the municipality may decide to launch an address investigation. This may include a home visit by the municipality. Selection of a high-risk address does not automatically lead to an adjustment of the address data in the BRP. It can only do so if the municipality sees reason to do so after conducting its own investigation. There is no automatic decision-making in this algorithm. There is always human intervention by the municipality's official and the LAA partnership, which consists of signal providers, RvIG, the VNG and the NVVB. The decision of a municipality to change the address data in the BRP can be objected to.

Human intervention

The profile is regularly evaluated with the eye of RvIG and municipalities on whether it still works, needs to be adjusted or has lost its effectiveness and should no longer be used. In this way, efforts are made to minimise the privacy impact on Dutch citizens. There is no automatic decision-making. Algorithms are a tool and are not leading. Assessment and decisions are ultimately always made by people. Before the municipality proceeds to adjust or change the BRP address, it always does its own address research. There is therefore no question of automatic decision-making.

Risk management

Privacy is potentially compromised, due to the processing of personal data and home visits by municipalities.

Legal basis

Under the Basic Registration of Persons Act (BRP Act), the Minister of the Interior and Kingdom Relations may process personal data for the purpose of creating and applying algorithms. The Act and rules based on it specify what kind of personal data is involved. So the minister is not allowed to process all kinds of personal data just like that. The law and regulations set limits to this. For instance, the minister may not process personal data relating to nationality, place of birth or data derived therefrom that results in discriminatory selection of persons. Nor may the minister process criminal data.

The General Data Protection Regulation (AVG) is also taken into account when creating algorithms.

RvIG carries out the task of processing personal data for LAA on behalf of the minister.

Links to legal bases

Wet BRP: https://www.rijksoverheid.nl/documenten/regelingen/2023/05/01/ministeriele-regeling-landelijke-aanpak-adreskwaliteit-laa

Operations

Data

CJIB data such as the period in which the mail item came undeliverable return (OBR), address details of OBR, Citizen Service Number (BSN) of the person concerned, Date indicates when the mail item was sent to the person concerned, The date on which the mail item came undeliverable return (OBR), The number of times of the case the mail item came total undeliverable return (OBR), The unique number given to the case by the Central Judicial Collection Agency (CJIB). It is needed for the CJIB feedback.

The data from the Basic Registration of Persons (BRP) such as number of people registered at an address and the data from the Basic Registration of Addresses and Buildings (BAG) such as living area per address and the function and status of the address.

Regulations state which data we are allowed to use in the algorithm. Data that is not mentioned is therefore not allowed to be used. Nor do we use (personal) data that could lead to discrimination. We do not select on nationality, place of birth or derivatives thereof.

Technical design

The model uses a simple decision tree. The selection rules are determined on the basis of analyses and domain knowledge within RvIG in consultation with municipalities. Data pre-selected by CJIB are used in RvIG's algorithm as input data. This data is delivered to the Information Exchange (IKP). The model, which IKP applies, uses a simple decision tree based on selection criteria. In the first step, all addresses that have "cell function" according to the BAG are removed. Then addresses that have been delivered to municipalities in the previous 365 days are removed. Then, based on up-to-date information from the BRP and BAG, the IKP checks whether the addresses still meet the selection criteria of the profile. The remaining addresses are further refined based on calculation rules developed from practical experience and past results. Addresses with a relatively low probability of incorrect registration are removed. Addresses with a relatively high probability of incorrect registration are delivered to the municipality. The municipality decides independently for each delivered address whether an address search is necessary or not. The municipality shares the results of its LAA work with the IKP. These results are analysed and used in consultation with the domain expert for further refinement and exclusion of addresses.