Flowchart about a process within the Municipality of Amsterdam.
18/9/2023
2
min. leestijd
Corporate Lawyers

Navigating through the GDPR: legal design tool for the Municipality of Amsterdam

The AVG poses complex issues for governing bodies. Because what should and should not be done with (sensitive) personal data? Good design offers the answers.
Savannah Koomen

The life behavior test

Are you applying for a permit to open a restaurant? Or do you want to work as a manager in a café? For these — and many more — applications, the municipality tests whether you are “of poor living behavior”. In addition, the municipality looks at criminal offences or suspicions, among other things.

This is sensitive personal data, which is strictly regulated by the GDPR.

For the licensing staff of the municipality of Amsterdam, it was unclear what they could and could not do with this data. This not only provides a compliance risks, but it also does not improve internal efficiency and workload.

Previous solutions were not effective

The municipality's legal team has tried to remove the ambiguities with a memo and an FAQ document with common questions. But this memo and FAQ were unable to provide licensing staff with insight into what is allowed and what is not allowed.

The solution: the life behavior test flowchart

The legal office of the municipality of Amsterdam mastered the principles of legal design during the Legal UX Design Workshop. In addition, the team set to work on translating the memo into a practical guide for licensing staff, in the form of a flowchart.

We further developed this flowchart in cooperation with the legal office and the Life Behaviour Test Expertise Group. The easy-to-navigate tool, with “yes” or “no” answers, provides each employee with clear guidelines on how to handle personal data when carrying out a life behavior test. In short: a tool that really helps permit employees.