The announced mobile application aimed at providing quick information to health authorities about the identity of the people with which the infected person has been in close proximity in the past 14 days has been developed and is available to the citizens of the Republic of North Macedonia. StopKorona! is intended for detecting close contact with potentially infected persons through a procedure for detecting proximity to mobile devices/applications via Bluetooth technology, and its use is based on the consent of the subject of personal data, i.e. voluntary downloading the application.
Before downloading the mobile application, it is recommended that citizens read the Privacy Policy and get acquainted with how their personal data will be protected, what are their rights as subjects of personal data and what are the obligations of the person who processes personal data collected through the mobile application.
After the analysis of the Privacy Policy available at stop.koronavirus.gov.mk, it can be noticed that it contains most of the information needed to inform citizens, and thus respects the principle of transparency in personal data processing.
The recommendation for improving the Privacy Policy is in the direction of providing additional information regarding the following issues:
- contact information from the Ministry of Health and/or the Personal Data Protection Officer where every citizen will be able to apply for the right to access, correct or delete personal data;
- in which cases will the Ministry of Health share the data collected through the mobile application with other institutions involved in the process of dealing with COVID-19; and
- information on whether the Ministry of Health intends, at some point, to transfer personal data to a third country or international organization.
According to the Law on Personal Data Protection, and following the principle of transparency in the processing of personal data, when personal data is collected by citizens, the controller, in this case the Ministry of Health, at the time of collecting personal data, provides the following information: identity and contact details of the controller, contact details for the personal data protection officer, the purposes of the processing for which the personal data are intended, the legitimate interests exercised by the controller or a third party, users or categories of users of personal data (if any), information on whether the controller intends to transfer personal data to a third country or international organization, the period for which personal data will be stored, the existence of the right of the controller to require access, correction or deletion of personal data, the existence of the right to withdraw consent at any time, the right to submit a request to the Agency for Personal Data Protection, information on whether the controller intends to further process personal data for a purpose other than that for which personal data is collected.
Additionally, the Privacy Policy may contain information and contacts from the institutions responsible for enforcing the laws in the field of personal data protection.
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The Metamorphosis Foundation, through its program Human Rights Online, represents human rights online, helping communities cope with the enormous changes that result from the growing influence of new technologies. Metamorphosis focuses on protecting privacy by strengthening the capacity of citizens, institutions and the business sector to function in a digital society.
