"Personal Information in Public Project Land Compensation Documents: Last Digits of Resident Registration Numbers Must Be Redacted"
Full Resident Registration Number Exposure Violates Principle of Minimal Data Collection
"Routine Collection Could Lead to Greater Harm in Case of Data Breach"
A recommendation has been issued stating that public institutions should not require landowners to submit copies of identification cards with their full resident registration numbers exposed when obtaining letters of recommendation for appraisers during the compensation process for public projects.
The Anti-Corruption and Civil Rights Commission announced on the 30th that public institutions, as project operators for public initiatives, should revise the letter of recommendation template for appraisers to minimize the collection of personal information from landowners.
Anti-Corruption and Civil Rights Commission, Government Complex Sejong.
Photo by Hyunmin Kim
Mr. A, a landowner affected by a public project, was asked by a public institution to fill in a resident registration number on the appraiser recommendation letter and attach a copy of his ID card. Mr. A filed a complaint with the commission, arguing, "Identity verification can be adequately achieved with just a signature and contact information" and "It is excessive to mandate the submission of an ID card copy containing sensitive information such as the resident registration number."
However, the public institution maintained that strict identification is essential to prevent identity theft, duplicate recommendations, and errors in the compensation process, citing the Enforcement Decree of the Act on Acquisition of and Compensation for Land, etc. for Public Works Projects as its basis.
The commission recognized the need for identity verification and determined that requesting a copy of an ID card is permissible. However, it pointed out that collecting the full resident registration number may violate the principle of minimal personal information collection. The commission further noted that collecting such information without explicit legal grounds could constitute a violation of the Personal Information Protection Act. It also considered that if the practice of collecting the unredacted resident registration number continues out of habit, the consequences could be severe in the event of a data leak. Accordingly, the commission recommended revising the forms to require redacting the last digits of the resident registration number.
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Min Seongsim, Director of the Grievance Settlement Bureau at the commission, stated, "Sensitive personal information of citizens should not be collected as a matter of routine for the sake of administrative convenience," adding, "We will closely monitor whether the principle of minimal data collection is being followed in practice."
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