The Republic of Srpska

         The Republic of Srpska Ministry of the Interior sent a letter to all institutions competent for processing of citizens’ personal information and the procedures for issuing digital certificates in order to warn them that the Agency for Identification Documents, Registers and Data Exchange of Bosnia and Herzegovina (IDDEEA) is abusing its legal competence for providing technical support to the ministries of the interior in BIH. Thus, IDDEEA is threatening the protection of citizens’ personal information. IDDEEA has initiated the process of illegal issuing of digital certificates, and introducing remote signature and digital wallet. These are not regulated by law in BIH and violate the protection of citizens’ personal information. It is important to note that, at the level of BIH, there is no legal framework for establishing digital identity in accordance with EU regulations, so it is necessary to harmonise the legal system with EU regulations adopted at the level of European Union this year before any activity related to digital identification and trust services. Digital identity is closely connected to the information security, and, since there is no legislation in this field at the level of BIH, the risk of information abuse is thus significantly increased. The provisions of the Law on IDDEEA (Official Gazette of BIH, no: 56/08) clearly specify the powers and competence of IDDEEA. These also regulate the keeping and technical design of databases, database management, and provision of other technical conditions for unobstructed database functioning. According to the Law on IDDEEA, it is the ministries of the interior that are competent authorities that cooperate with the Agency and process and own the citizens’ personal information. Regarding their rights related to personal identity cards, including the qualified digital certificates related to identity cards, which IDDEEA announced they had the intention of issuing, citizens may only and exclusively address the ministries of the interior which adopt decisions in administrative procedures in accordance with their legal competence. Every other procedure that includes accepting requests of citizens in IDDEEA offices, as IDDEEA announced, is illegal and represents serious abuse of authority.