III. DISCUSSION OF THE DRAFT NATIONAL ELECTIONS LAW AND THE DRAFT ELECTION COMMISSIONS LAW

L. Voter lists

Article 16 contains two very short sentences stating that the “record of voters is made via a unified system” and “the Law shall regulate the use and formation of the unified system.” It would appear that a separate law is intended to regulate the collection and use of data on citizens for purposes of establishing the “unified system”. No opinion is expressed herein concerning the collection, maintenance, dissemination, or subsequent destruction of personal data on citizens contained in the “unified system”. However, the Venice Commission and OSCE/ODIHR recommend that such data be collected and maintained in a manner that is consistent with recognized principles for the protection of personal data of citizens.[1] 

[1] See, e.g., Convention 108 of the Council of Europe for the Protection of Individuals With Regard to Automatic Processing of Personal Data and The Explanatory Report (28 January 1981), which provides detailed discussion as to what safeguards should be in place. See at: http://conventions.coe.int/Treaty/en/Treaties/Html/108.htm.