AI and civil affairs: why the population register is not just another source

By · Updated · 2 min read

Short answer

A population register holds data on every resident, and access is authorised per use. An AI assistant that can search the register freely would bypass those authorisations. So let AI help with procedures, forms and residents’ questions, and connect only specific, authorised queries to an automation, with its own identity and full logging.

Why the register is different

A population register, such as the Dutch Basisregistratie Personen or the German Melderegister, is used by public bodies for their own tasks, but only for the data and purposes they are authorised for. National identification numbers may only be used where the law allows. Within an authority, staff get access that fits their role.

An assistant that can search the whole register removes those boundaries: a question such as "who lives at this address?" would become answerable for every user. That is exactly what the authorisation system is meant to prevent.

What does work

ApplicationAccess to personal data
Questions about procedures, fees and required documentsNone
Searching work instructions and regulations for staffNone
Letters and explanations in plain languageOnly what the employee enters
Checking submitted documents for completenessThe documents of that application
A specific, authorised query inside an automationOnly that item, for that purpose, logged

How to set it up

  1. No open connection. The assistant gets no general access to the register as a searchable source.
  2. Automation with its own identity. If a process needs to look something up, an automation does so with its own narrowly authorised account. See Access control for AI.
  3. Safeguards on ID numbers. Block national ID numbers and other identifiers in free input, so they do not end up in prompts where they are not needed.
  4. Logging and review. Every query is traceable to a person or automation, and included in your own review of register use.
  5. DPIA beforehand. See A DPIA for generative AI, and include the application in your security accountability. See AI and information security.

How werqly fits in

With werqly the assistant runs on a dedicated node in the authority’s network. In werqly AI Control civil affairs gets its own role, safeguards block ID numbers per role, and automations run with their own identity. The audit log shows who queried what. See AI for local government.

Frequently asked questions

Questions on this topic

May an AI assistant search the population register?

Not as an open source. Access to the register is authorised per use and purpose, and an assistant that can search the whole register bypasses those limits. An automation may at most look up a specific, authorised item, with logging.

Where can AI help civil affairs?

With questions about procedures and required documents, searching work instructions and regulations, plain-language letters and checking submitted documents for completeness. None of that needs access to the register.

How do we keep ID numbers out of prompts?

With safeguards that recognise national ID numbers and other identifiers and block them per role before they reach a model, and with clear instructions to staff on what they may and may not enter.

Is a DPIA needed?

For applications that process residents’ personal data, especially if they touch the register, almost always. Record in the DPIA which data, for what purpose, with which authorisation and which logging.

Sources

  1. Dutch Personal Records Database Act (Wet BRP)
  2. GDPR (Regulation (EU) 2016/679), Article 35 (DPIA)

This article is general information, not legal advice. Rules and guidance change; check the sources listed or ask your lawyer or DPO if in doubt.

About the author

Tim Hoogstrate

Founder of werqly

Tim Hoogstrate is a software developer and the founder of werqly. He writes the articles in the knowledge base: what the GDPR, the AI Act and sector rules require when you use AI, and how to arrange that in an environment of your own.

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