Abstract
This memorandum focuses on the jurisdictions of the United Kingdom (UK), Germany and the United States (US) to provide contrasting examples of data protection principles and of anti-fraud systems similar to SyRI.
Systems with similar or resembling objectives as SyRI, namely the prevention of social welfare fraud or medical fraud, were analysed with regard to the UK and the US. Both jurisdictions’ national justifications for use of the systems were always the combatting and prevention of fraud and meeting the public demand to prevent crime and misuse of public goods. This is identical to the justifications for the use of SyRI in the Netherlands. Within the parameters of the research, no system in Germany was found which shares data between governmental institutions with the purpose of the prevention of fraud. The legal framework regarding data protection is however quite extensive and has been analysed in order to provide for a comparison to some of the principles governing SyRI.
Systems with similar or resembling objectives as SyRI, namely the prevention of social welfare fraud or medical fraud, were analysed with regard to the UK and the US. Both jurisdictions’ national justifications for use of the systems were always the combatting and prevention of fraud and meeting the public demand to prevent crime and misuse of public goods. This is identical to the justifications for the use of SyRI in the Netherlands. Within the parameters of the research, no system in Germany was found which shares data between governmental institutions with the purpose of the prevention of fraud. The legal framework regarding data protection is however quite extensive and has been analysed in order to provide for a comparison to some of the principles governing SyRI.
| Original language | English |
|---|---|
| Publisher | Public Interest Litigation Project, Nederlands Juristen Comité voor de Mensenrechten |
| Number of pages | 23 |
| Publication status | Published - 31 Mar 2016 |
