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avis-n0-62-2025.pdf

Here are the key points from the document:

General Points

  1. The Authority is inviting comments on a new project related to the processing of personal data.
  2. The project aims to modify existing decrees and regulations regarding the provision of services for job seekers.

Specific Recommendations

  1. The Authority recommends that the project be delayed until modifications are made to the relevant legislative texts (points 9-11).
  2. "Information from the return of enterprises" (art. 6) should either be requalified to match the terminology in art. 13 of the 2021 decree or omitted from the project (point 21).
  3. If certain categories of data are specified, the project should indicate that it also aims to execute art. 4/3, §1er of the FOREM decree (point 23).

FOREM Decrees

  1. Treatments of personal data performed by the service control must have a specific framework (point 18).
  2. It would be appropriate to provide a specific framework for data banks used by the service control (point 19).
  3. The concept of "operators who intervene in the job seeker's career" should either match an actor defined in the decree or be removed (point 20).
  4. Precisions regarding information from other FOREM services, currently present in art. 6 of the 2022 decree, must be included in the decree (point 22).

Data Protection

  1. The Authority highlights the importance of respecting the principle of accuracy and up-to-date data processing.
  2. If a decision is made to rectify personal data, it should trigger a procedure to restore the individual's rights and provide compensation.

Conclusion

  1. The Authority invites comments on the project, referencing previous opinions (90/2020, 94/2022, and 53/2025).

Note: The points are numbered based on the original document, and some minor rephrasing was done to make them more concise and clear.

Published: 2025-08-12 · Source: APD

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