The collection by the authorities of the Ministry of Interior of declarations from citizens passing through the checkpoints in the regional cities of the country is a temporary measure and concerns a limited number of persons whose data is processed.
In the context of the declared state of emergency on 13March by the National Assembly of the Republic of Bulgaria on the entire territory of the countrydue to the rapid spread of the virus (COVID-19)threatening the life and health of the population and on the grounds of the State of Emergency Measures and Actions Act declared with the Decision of the National Assembly of 13March 2020, effective from 13March 2020 until the state of emergency is repealed (Promulgated, SG No 28 of 24March 2020), it should be noted, that:
1. The data protection legislation allows for the possibility of limiting the scope of citizens’ rights and freedoms pursuant to Article 23 of Regulation (EU) 2016/679;
2. In this case, the measure imposed by MoI is necessary and proportionate in the view of safeguarding the:
• public health; and
• prevention of criminal offences (such as the act under Article 355 of the Penal Code), including the safeguarding against and the prevention of threats to public security, the threat of the spread of the virus being such undoubtedly.
The citizens shall be assured that the possibility of restricting their rights, including the right to protection of their personal data, does not lead to the their violation!
In this regard, the legislation does not in any way exclude the obligation of MoI to process data solely for the purposes of the State of Emergency Measures and Actions Act, as well as to guarantee the security of the processing of personal data contained in the declarations by applying appropriate technical and organizational measures!
