The information demand Number of residents at address

National Authority for Identity Data

This algorithm is used to display on MijnOverheid the number of residents at the logged-in person's residential address.

Last change on 13th of December 2024, at 14:18 (CET) | Publication Standard 1.0

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

General information

Theme

Organisation and business operations

Begin date

2023-11

Contact information

[e-mail]

Responsible use

Goal and impact

The purpose of the algorithm is to provide targeted information to organisations using the BRP (users), rather than loose data that users have to process into information themselves. The algorithm converts the loose data into information, based on rules. That information is provided to users from the central BRP, rather than the entire set of data needed to arrive at that information. As a result, less data is provided to BRP users; this achieves data minimisation.

In addition to data minimisation, the deployment of algorithms in the BRP APIs has the following objectives.

• Preventing errors in the use of BRP data, such as incorrect derivation of the acquisition name based on separate name data, so that citizens' rights are protected as much as possible.
• More transparency for citizens; citizens can also see how the data has been used because the derivation rules are public (the derivation rules used by BRP users themselves are mostly not known and, moreover, differ from one user to another).
• Long-term cost savings:
• because BRP users no longer have to manage copy files;
• lower connection costs to the BRP for users;
• centralisation of rules at the provider of BRP data, instead of implementation at many users;
• Faster and cheaper implementation of changes to the BRP due to social developments. Organisations now use rules themselves -each on their own- to derive information from BRP data. With the BRP APIs, deriving information from BRP data is done centrally. By centralising these rules, the impact of a change on connected government systems is much smaller than now.

Considerations

The deployment of the algorithm provides benefits because the central processing ensures that less (sensitive) data is provided to users. These are government organisations, municipalities and other organisations performing a statutory task. By deploying the algorithm, there is less risk of unlawful processing of personal data. And the negative consequences that may arise from data breaches are reduced. The information query Age is used by organisations that need only the person's age, and not the date of birth, to carry out their processes.

The only alternative to RvIG centrally processing the personal data is for users to process the data into information themselves - if required. This is the current practice. This means that the data from the BRP must first be provided to the user, after which the user himself edits the data into information. This represents a major invasion of the citizen's privacy compared to the use of the algorithm, as more personal data is provided than would happen with the algorithm. It also entails each user having to develop their own 'computational rules' to convert the data - if desired - into information. As a result, the same data may yield different information at different organisations. For example, mistakenly counting people with a letter address or deceased people as residents.

Human intervention

The algorithms of the BRP APIs are limited to information queries and answers that are more factual in nature and usable in an equal way by all BRP users. It is up to the user to request additional information, depending on the situation in which the information is used. Article 2.7 of the Experimental Decree on Data Minimisation contains a regulation on making a feedback when the user doubts the correctness of the information received.

Risk management

The risk of errors in processing, resulting in incorrect information being provided to the buyer on the basis of which wrong decisions are made, is covered by:

• The ability to deviate from the information provided;
• A procedure at the processor, the Rijksdienst voor Identiteitsgegevens (RvIG), for reporting potentially incorrect information;
• Extensive and structured testing in advance.

The risk that verification and correction by the data subject becomes more difficult because the information provided is generated on a transaction-by-transaction basis is covered by:

• The possibility for the recipient to deviate from the information provided;
• A procedure at RvIG for reporting potentially erroneous information.

The risk of repeating errors in processing due to the fact that BZK is not authorised to correct basic data on person lists is covered by:

• The possibility for the recipient to deviate from the information provided;
• A procedure at RvIG for reporting potentially incorrect information.

The risk of changing calculation rules without following the necessary procedures is covered by:

• Following standard procedures when adding, changing or deleting calculation rules;
• Following the regulatory process.

The risk of fragmented assessment of effects of information provision per customer is covered by making agreements in the covenant.

The risk of automated decision-making without human intervention is covered by making agreements in the covenant.

The residual risk is estimated as LOW for all risks mentioned above.

Legal basis

The Key Register of Persons Act (BRP) provides the basis/frameworks for recording (and updating) and providing personal data (Chapters 2 and 3 of the BRP Act). The BRP Act itself provides no basis for processing data into information that can be traced back to a person. However, Article 4.16a of the BRP Act does offer the possibility to temporarily deviate from provisions in the BRP Act by order in council (AMvB) for the purpose of data minimisation. This possibility is taken advantage of with the Experiment Data Minimisation BRP Decree: this AMvB, in conjunction with the BRP Act, provides the basis for processing and providing information. The covenant is a condition for either being allowed, as a Municipal Executive, to consult the API to provide information within the municipality or, as a user of the BRP (government body or third party), to be provided with information.

Links to legal bases

• Experimentbesluit dataminimalisatie: https://zoek.officielebekendmakingen.nl/stb-2024-96.html
• Wet Basisregistratie Personen: https://wetten.overheid.nl/BWBR0033715

Link to Processing Index

https://www.avgregisterrijksoverheid.nl/verwerkingen/uitvoering-wet-basisregistratie-personen

Impact assessment

Data Protection Impact Assessment (DPIA): Opvraagbaar via [e-mail]

Operations

Data

Citizen service number

Residence identification code

Suspension date

Function address

Indication of data under investigation address

Links to data sources

Logisch Ontwerp BRP: https://www.rvig.nl/lo-brp

Technical design

To answer the information question, the following conditions apply:

1. The person lives in a Dutch municipality;
2. The person is not deceased;
3. A valid address is registered for the person in the BRP;
4. The person's current address is a residential address, not a postal address.

If the person does not meet one or more of these conditions, the answer will state that the number of residents could not be retrieved.

If the person with the BSN meets all the above conditions, then:

1. All persons registered at the same address are searched;
2. Are checked all persons found meet the conditions applicable to the person requested;
3. All persons meeting the above conditions are counted, including the requested person himself.

External provider

Developed internally, in collaboration with Logius.

Link to code base

https://github.com/rvig-publicaties/BRP-V/tree/main/Webservices-Specificaties/lrdplus1-1.zip