model-privacy-protocol-ondermijning

name: model-privacy-protocol-ondermijning description: Reference guide for the Model Privacy Protocol on intra-municipal data exchange for combating undermining crime (ondermijning). Use for phase guidance (1–4), privacy checks (1, 2A, 2B), proportionality/subsidiarity, and legality/compatibility assessments.

Model Privacy Protocol (Ondermijning) — Skill Reference

Overview

This skill provides quick, accurate guidance based on the Model Privacy Protocol for binnengemeentelijke gegevensuitwisseling (intra-municipal data sharing) in support of the administrative/integrated approach to undermining crime (ondermijning).

It helps users navigate:

The 4-phase workflow (signal intake → weighting → source check → plan of approach)
The two privacy check moments (Privacy check 1; Privacy check 2A/2B)
The required legal reasoning: purpose limitation / compatibility, necessity & proportionality, and subsidiarity
Practical safeguards: retention, information duties, and data minimization

When to Use

Use this skill when you need to:

Explain or apply Phase 1–4 steps in the protocol
Decide whether a signal is in scope (ondermijning + municipal task + municipal territory)
Determine whether you may query sources using hit/no-hit
Decide whether gathered data may be shared internally for case handling (2A) and for executing the chosen approach (2B)
Clarify privacy/legal guardrails (AVG/UAVG + sectoral laws) and required documentation

What This Skill Covers

Phase Summary (Protocol Workflow)

Phase 1 — Receipt & intake of the signal

Qualify: does the signal relate to ondermijning (using the checklist / indicators)?
Check: is there a municipal task or power that could apply (2A)?
Check: does it concern the municipality’s territory (2B)?

Phase 2 — Weighting the signal

Assess severity/concreteness/relevance using objective local criteria.
Decide: no action vs route internally vs route externally/RIEC vs continue to Phase 3.

Phase 3 — Source research (Bronnenonderzoek)

Execute Privacy check 1 to determine:
- which municipal sources may be queried
- hit/no-hit first (data minimization), then only relevant “what-information” if justified
After hits: weigh results and decide whether to move to Phase 4.

Phase 4 — Plan of approach (Plan van aanpak)

Before the signal/case meeting: do Privacy check 2A (what may be shared for deciding the approach).
After approach is chosen: do Privacy check 2B (what sharing is allowed/necessary to execute the approach + intended legal powers).

Privacy Checks (Core Logic)

Privacy check 1 (start Phase 3) Answer per case: A) What is the legal basis of the primary collection/use of the data?
B) Is further use for “combatting undermining” compatible with the original purpose?

Apply the compatibility factors (context, data type, impact, safeguards, etc.) C) Is it necessary & proportionate, and does it meet subsidiarity?
Start with hit/no-hit where possible; avoid opening underlying details unless needed.

Privacy check 2A (start Phase 4)

Which of the gathered Phase 1–3 data may be shared with which internal participants to determine the approach?
Share only with the domains that need it (role-based minimization).

Privacy check 2B (during Phase 4 execution planning)

Given the chosen intervention and legal powers, confirm whether additional internal sharing is:
- legally allowed (sectoral regime may restrict)
- necessary and proportionate for the concrete execution

Inputs This Skill Expects

Provide (as available):

The signal (what happened, when, who/what is involved)
Whether it concerns an object (location/premises) or subject (person/entity)
The suspected phenomenon (e.g., exploitation, drugs, fraud, etc.)
Intended municipal task/power you think might apply (if known)
Which internal domains/sources might be relevant (if known)

Outputs This Skill Should Produce

Depending on the request, return one of:

A phase-by-phase next step (what to do now, what to document)
A privacy check decision summary, including:
- primary legal basis
- compatibility reasoning
- necessity/proportionality/subsidiarity notes
- “hit/no-hit first” guidance
A sharing recommendation for Phase 4:
- who can receive what data (2A)
- what additional sharing is allowed for execution (2B)
A short risk/guardrail note: retention, transparency/information duties, and limits

Guardrails & Non-Goals

Do not invent legal permissions. If the applicable sectoral regime is unclear, state what must be verified.
Prefer minimal data use and hit/no-hit before opening detailed records.
The protocol is a model; municipalities must adapt it to local structure/policy