An open appeal regarding the transfer of the personal data of individuals to the private debt collecting company

Based on the agreement between the State enterprise “The major design, manufacturing and service center of computer and finance technologies” (“Holovfintech”) of the Ministry of Finance of Ukraine and the debt collecting company “Delta M Ukraine”, the company has received personal data of citizens of Ukraine. The relevant agreement was signed as a result of two successful tenders for the implementation of verification by telephone and direct contact (UAH 999,999.00 and 987,000.00, respectively).

The decision to transfer personal data of citizens of Ukraine to a private company dealing with the debt collecting activity, undermines the trust in the system of verification of social payments, even if the relevant verifications are indeed crucial for the state. We believe that public policy control over budget expenditures can be efficient only if it is legal and when it does not pose a risk to the public safety, does not violate the citizens’ rights and does not create new threats to the national security.

The Ministry of Finance of Ukraine and its State Enterprise “Holovfintech” blatantly violated Ukrainian legislation and standards of protection of personal data and neglected the human right to private life. In an open letter, the Ukrainian Parliament Commissioner for Human Rights Ms. Valeriya Lutkovska stated: “I am convinced that this situation is not only a rude violation of the right to privacy of many individuals, but that it also constitutes a threat to the image of our country on the international arena. One of the key conditions for Ukraine to enter the European community is to create an efficient mechanism for the protection of personal data which would comply with the international standards in this area”. 

At the same time, the information, given by the Ministry of Finance of Ukraine on the request of media outlets, stated that only the names and telephone numbers of recipients of social payments had been transferred to “Delta M Ukraine”, - which is false to our knowledge. This also was proved by the tender documentation published on the state tender website Prozorro.

The fact that citizens’ personal data have been transferred to a private debt collecting organization led to the following consequences:

1. The violation of the right to personal data protection. Despite the public statement of the Ombudsman, the Ministry of Finance of Ukraine has not provided any information that would give minimum guarantees on the control of the use of the personal data that have already transferred. According to comments on NGO “Group of Influence” hotline (+38050 477 0800), any person calling the call center of “Delta M Ukraine” can easily get personal information about a citizen, having only his/her telephone number. Therefore, there are reasons to assume that the data is not adequately protected and that it can be used for any purpose.

2. The violation of the right to privacy, which has already occurred after the transfer of data to a third party. The right was further being violated by the results of a tender for direct contact (“physical”) verification. According to Annex # 3 of the tender documentation for the procurement of services for direct contact verification, “the aim of collecting (verifying) information, is personal data verification, checking the place of residence, the place of work of individuals, photographing the residence of individuals, in order to prove the reliability of the information they preliminary provided”.

3. Involving a debt management company to perform a governmental function potentially creates conditions for a psychological violence against citizens, taking into account the specific methods of debt collection activities. In particular, the hotline was contacted by a woman, who reported that after her refusal to speak with an unknown person over the phone, the “Delta M” call center operators called her 8 times a day from different phone numbers and used methods of psychological influence.

4. The international activity of the group of companies “Delta M”, including in the Russian Federation, creates a risk that non-Ukrainian residents get an access to the personal data of Ukrainian citizens. In the case of internally displaced persons, such situation is particularly unacceptable, providing a possibility of illegal activity towards them and their relatives in the non-government controlled areas. The same situation is also unacceptable for other categories of citizens of Ukraine, whose personal data can be transferred to private entities.

5. In addition to the legal aspects of compliance with the standards of protection of personal data and privacy of life, the damage to the state associated with the risk of uncontrolled dissemination of personal data of IDPs, should also be considered. Taking into account the ongoing peace-building process and overcoming the effects of external aggression, the access to internally displaced persons’ database by non-state actors creates a risk of personal data abuse to intimidate the citizens.

6. With regard to the potential organization of an election process on the non-government controlled areas in Donetsk and Luhansk regions, the dissemination of the personal data of internally displaced persons and the access to it by a third party can be a particular risk for the putting together of voters’ lists and create some obstacles to the free will of citizens. For example, in the case representatives of illegal armed groups would receive personal data, there is a probability of intimidation activities towards voters by phone or other ways.

Supporting the Ombudsman’s claim to stop violations of human rights and standards of personal data protection, we call for:

The Prime Minister of Ukraine and the Ministry of Finance of Ukraine -

- To cancel the decision of the SE “Holovfintech” on the transfer of personal data of citizens of Ukraine and, under the supervision of the Ukrainian Parliament Commissioner for Human Rights, to ensure the removal and destruction procedure of illegally transmitted information;

- To conduct an internal investigation resulting in the prosecution of the perpetrators according to the Ukrainian legislation;

- To regulate the process of verification of social payments, which would protect citizens from further human rights violations and would ensure the trust in public authorities.


The Head of the Security Service of Ukraine, the Prosecutor General of Ukraine –

- To study all the circumstances relative to the transfer of personal data to the private debt collection company, including the establishment of a clear period of time when the “Delta M Ukraine” has received access to personal data, by whom and according to which regulations it was made;

- To establish the fact of the use of personal data of citizens of Ukraine received from government agencies, for purposes which do not correspond with the objectives of the social payments verification process;

- To prevent the possibility of further dissemination of personal data between different subjects, including foreign organizations and illegal armed groups.


NGO Public holding “Group of Influence”

Charitable Foundation “East-SOS”

NGO “Donbas SOS”

NGO “CrimeaSOS”

Civil Network “OPORA”

CF “Stabilization Support Services”

Coalition of patriotic forces of Donbas

Resource Center for internally displaced persons

Human Rights Information Center

International Double Standards Institute

Ukrainian Helsinki Human Rights Union


Civic Association “Security and Cooperation in Ukraine”

Center for Civil Liberties/EvromaidanSOS

No Borders Project of the “Social Action Centre” NGO

NGO “Lugansk human rights group”

NGO “NewDonbas”

NGO "Crimean Diaspora"

Charitable organization "Battalion "Donbas" aid charitable foundation"

Charity foundation SVOYI

NGO "Lugansk’s Public Initiative"

Charitable organization Charitable foundation "GurtOM”


Contact person: Tetyana Durnyeva (NGO Public holding “Group of Influence”)

+38 067 705 85 85,