Union of Lithuanian Poles – VDAI warning

According to the Inspection report, this decision was made in light of the failure of the Polish Union to provide the requested documents and in light of all its obligations regarding the processing of personal data.

In January, the Union of Poles of Lithuania announced that it was preparing a census of the Polish national minority in parallel with the general census conducted by Statistics Lithuania.

It was indicated that the census in the Vilnius region will be organized electronically, by telephone and directly.

“We are announcing the initiative so that we can mobilize our population, pay attention to the fact that human identity and nationality registration are very important,” said Edita Tamošiūnaitė, vice president of the Union of Lithuanian Poles in Vilnius.

According to her, the available data will allow the community to define and predict more precisely the needs of kindergartens, schools and cultural activities of national minorities. The data collected was intended to be stored for 25 years.

In response to these reports, the SDPI approached the Union of Poles of Lithuania to clarify the legality of the processing of personal data and requested the submission of documents related to this initiative: questionnaire form, data protection impact assessment, notification to individuals about their data processing. , data security documents and data processing activities.

The Inspection emphasized that personal data can only be processed in accordance with the requirements of the General Data Protection Regulation (BDAR).

“Special categories of personal data, such as in the initiative of the Polish Union of Lithuania” Public Census of Population of the Vilnius Region “, when applying for nationality (ethnic origin), are more sensitive and therefore require even more protection, since their prosecution may represent a greater risk to human rights and fundamental freedoms, “says the inspection report.

Data on the nationality and ethnic origin of a person are considered special categories of personal data and their processing is prohibited, with certain exceptions. In addition, the person must give their explicit consent.

According to the Inspection, the Union of Poles of Lithuania must prove that the consent to process your data was given by the person who proved for what specific purpose the consent was given and when it was given.

SDPI also believes that the initiative of the Union of Lithuanian Poles, carried out in the same way as the general census conducted by the Department of Statistics, could mislead people, “therefore, it would be considered incompatible with the principle of equity “. .

Since the Inspectorate did not receive the requested documents from the Polish Union, the Inspectorate states that it has no reason to conclude that the intended processing of personal data will comply with the BDAR.

In January, the Department of Statistics launched a statistical survey on the nationality, mother tongue and religion of the population. A general census is also carried out, but it is carried out based on the data available to the state, administrative sources and the enumerators no longer visit the population.

According to data from the 2011 Population and Housing Census carried out by the Department of Statistics, 84.2%. of the total Lithuanian population were Lithuanians, 6.6%. – Poles, 5.8 percent. – Russians, 1.2 percent. – Belarusians, 0.5 percent. – Ukrainians, 0.6 percent. – residents of other nationalities.