The Commissioner for Information of Public Importance and Personal Data Protection informs all citizens who intend to participate in the prize game “Receipt for a Win” that they have no obligation to write their Unique Personal Identification Number on the back of the envelopes which they use to send the fiscal receipts they collected in order to participate in this prize game. Such obligation lacks a proper basis, purpose or reason and would most definitely pose an unnecessary and serious risk of abuse of this complex piece of personal data.

Since the media and some officials have repeatedly insisted that citizens have the obligation to provide this information, the Commissioner has initiated an inspection of compliance with the Law on Personal Data Protection by the Ministry of Finance and has asked the Ministry for replies concerning a number of issues.

In its reply concerning the Unique Personal Identification Number, the Ministry of Finance explicitly stated that the Government’s resolution which set out the rules of this prize game “does not require this piece of information and the participants in the prize game are required to provide the following personal data: name, surname, address and contact phone.”

With regard to the fact that the instructions posted on the websites of the Ministry of Public Administration and Local Self-Government and the National Alliance for Local Economic Development (NALED) require this data, the Ministry replied those instructions contained “a technical error” and were not the official eligibility criteria. It also stated the error had been corrected and a new version of the envelope was printed without the designated space for entering the Unique Personal Identification Number.

However, as the media continue misrepresenting the situation, claiming that the Unique Personal Identification Number is required, the Commissioner would like to take this opportunity to advise citizens that they definitely have no such obligation.

The Commissioner will continue with the inspection procedure, in anticipation of replies by the prize game organisers to a number of unanswered questions, namely: Who are the recipients of the personal data? Which data protection measures have been implemented? And why did the organisers not previously notify the Commissioner of the intended personal data processing, as was their duty under Article 49 of the Law on Personal Data Protection?