Based on the increased public interest in connection with the Decision of the Government of the Republic of North Macedonia No. 40-678/25 of August 7, 2021, which was published in the Official Gazette of the Republic of North Macedonia on August 9, 2021, which, among other things, prohibits entry into any facility, including catering facilities, where there are more than 30 visitors/guests/persons present, for an event of any kind (celebration, party, wedding, birthday, christening, concert, seminar, training, workshop, conference, cultural or sports event), without possessing and attaching a certificate of immunization against the Sars-Cov-2 virus, at least the first dose of vaccine, starting from August 16, 2021, and from the aspect of whether the implementation of such a decision violates the right to privacy and the protection of personal data, the Personal Data Protection Agency reports on the following:
The law on protection of personal data applies only in the case where personal data is processed. Under the processing of personal data according to the Law is considered any operation or set of operations performed on personal data, or a group of personal data, automatically or otherwise, such as: collecting, recording, organizing, structuring, storing, adjusting or alteration, withdrawal, consultation, inspection, use, disclosure by transmission, publication or otherwise making available, matching or combining, restriction, deletion or destruction.
Therefore, we inform you that if only a visual inspection of the confirmation of immunization against the Sars-Cov-2 virus is carried out (regardless of whether it is in paper form or stored on a digital device) and no personal data is retained during this inspection, it does not constitutes “processing of personal data” and consequently, this activity is outside the scope of the Law on Protection of Personal Data.
Taking into account the above, and considering that the adopted Decision No. 40-678/25 of August 7, 2021, inter alia, prohibits entry into any facility, including catering facilities, where there are more than 30 visitors/guests present /persons, for an event of any kind (celebration, party, wedding, birthday, baptism, concert, seminar, training, workshop, conference, cultural or sports event), without possession and attachment on confirmation of immunization against the SARS-CoV-2 virus, at least the first dose of vaccine, starting from August 16, 2021, it follows that if during the implementation of this decision only a visual inspection of the confirmation of immunization against the SARS-CoV virus is carried out 2 (according to the principle of “attached” or “not attached” confirmation), such activity is outside the scope of the Law on the Protection of Personal Data and consequently would not constitute misuse of personal data.
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