Information commissioner Republic of Slovenia
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Linking filing systems

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Article 87 of the ZVOP-2 on linking in the context of the ZVOP-2 refer exclusively to the linking of personal data sets from those official records and public registers in which the following data is processed:

-       specific categories of personal data,

-       personal data relating to criminal convictions and offences,

-       data on income in accordance with the law governing income tax,

-       data on the assets of an individual in accordance with the law governing public funding,

-       information on immovable property owned by the individual in accordance with other laws,

-       data or information on creditworthiness in accordance with the law governing the Central Credit Register

-       and official records in accordance with the law governing the tasks and powers of the police and the law governing the prevention of money laundering and terrorist financing.

ZVOP-2 no longer requires to notify and obtain a decision from the Information Commissioner for connecting two or more personal data collections, however, before such official records and public registers can be linked to each other or to other collections, two conditions must be met, namely:

-       such linkage must be expressly provided for by law and

-       the controller or processor must have carried out an impact assessment under Article 35 of the General Regulation and consulted the Information Commissioner under Article 36 of the General Regulation before starting to link such collections.

The ZVOP-2 does not specifically regulate the linking of official records and public registers which do not contain the aforementioned types of personal data, which means that the linking of other official records and public registers is permissible provided that one of the legal basis referred to in Article 6(1) of the General Regulation exists for such processing and that adequate security of the personal data is ensured, including the provision of a processing log as referred to in Article 22 of the ZVOP-2.