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Bosnia: AZLP finds Sarajevo Housing Fund and Anti-Corruption and Quality Management Office's processing of personal data unlawful

The Agency for Personal Data Protection in Bosnia and Herzegovina ('AZLP') announced, on 7 July 2021, its decision in relation to a complaint against the Sarajevo Canton Fund for Housing Construction ('the Housing Fund') and the Office for the Fight against Corruption and Quality Management of the Sarajevo Canton ('the Office'), in which it found both institutions in violation of Article 4(1)(a) of the Law on the Protection of Personal Data No. 49/06 ('the Law'), following their processing of the complainants' personal data without a legal basis. 

Background to the decision 

In particular, the AZLP stated that the complaint against the Housing Fund and the Office was due to the former submitting the complainants' personal data on education to the latter, for further processing. In this regard, the AZLP noted that such personal data included that of the Housing Fund's employees, and relates to their acquisition of diplomas of secondary and higher education, including the title of the diploma as well as the institution that issued the diploma, all for the purpose of reviewing the diplomas of employees in administrative bodies and verifying their credibility. Moreover, the AZLP detailed that the complainants objected to the processing of such data by the Office, claiming that it lacks a legal basis. 

Findings of the AZLP

Notably, the AZLP found that the Office did not have a valid legal basis for collecting and processing the employees' personal data in violation of Article 4(1)(a) of the Law, and that the Office was not authorised to submit these to educational institutions to verify their credibility. 


Ultimately, the AZLP noted that no appeal is allowed against its decision, but an administrative dispute may be initiated before the Court of Bosnia and Herzegovina within 60 days from the date of delivery of this decision. 

You can download the decision, only available in Bosnian, here