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The center of registers (does not) have the technical capacity to provide information on co-owners under a unique code

In this review, I want to share a seemingly rather simple situation - there are cases where three legal entities are given one real estate code and one of them needs to receive the names, surnames or other personal data of the co-owners[1]. Information on co-owners must be provided to the applicant by the State Enterprise Centre of Registers (hereinafter - CR). To our company’s initial request for the above data, CR replied that it did not have the technical capacity to provide such basic information. However, after a month and a half of correspondence with various CR divisions, we received a response that there is a possibility to generate the data we requested for an additional fee, which is not mentioned in the CR price list.

CR[2] is currently under the Ministry of Economy and Innovation. CR was previously owned by the Ministry of Transport and Communications, before that, it was at the disposal of the Ministry of Justice.

It would seem that for such a solid company, the technical capabilities of information technology should be unlimited, unfortunately, de facto - it is the technical barriers that prevent CR from providing customers with targeted information that complies with the regulation of personal data protection.

Example:

 

The company has acquired one parking space in the parking lot.

According to the CR procedures, a unique parking space code is assigned to three adjacent parking spaces.

Generally speaking, one parking space under a unique code belongs to three persons - co-owners.

 


Raimda auditas UAB is located in a convenient place - in the city centre. Understandably, in the heart of the city, where there is particularly heavy traffic, every centimetre is important. In order to mark the parking place belonging to the company with the road sign “Reserved parking place”, we applied to the Road Police Board of the Kaunas Count Chief Police Commissariat.

The Road Police provided us with a detailed answer as to what documents are required to mark the relevant parking space with the “Reserved parking space” sign. One of the required documents was the written consent of the co-owners of the parking space to install such a sign. Official information on the co-owners of the parking place is provided by CR, which is why we have contacted this institution to provide the above information.

CR’s response was very surprising because instead of information about the two co-owners of the parking space, who were given the same unique code as Raimda auditas UAB, we received a 20-page response, which revealed a lot of information not related to the request.

THE ANSWER PROVIDED INFORMATION WITH THE PERSONAL CODES AND DATE OF ACQUISITION OF THE PROPERTY OF ALL APARTMENT OWNERS REGISTERED AT THE SAME ADDRESS!

We were very unpleasantly surprised by this response because making a request for information about the two co-owners of the parking space we received excess information that was completely unrelated to our request.

When we asked CR why we were given redundant, voluminous information that was completely unrelated to our request, we received an initial response - CR has no technical capability to provide information about co-owners by unique code, only by address.

In this almost comical situation, the question remains open - what about the provisions of the GDPR? Is such posting of personal data not a breach of the regulations? Does this practice of a public body with regard to personal data does not raise an issue with the authorities supervising the provisions of the GDPR?

Another question - should Raimda auditas UAB in such a case submit to the Road Police all 20 (twenty) sheets received from CR, or, nevertheless, be obliged to arbitrarily adjust the official information provided by CR in order not to violate the provisions of GDPR?

In mid-February, a month and a half after our initial inquiry, we received a CR’s offer to provide us with the specific service we requested. This service - preparation of a non-standard volume report - according to CR, is non-standardized, therefore fees applied to it are non-standard as well. Information about the two co-owners of the parking space can be programmed, and the cost of a programming hour is 50 euros.

It is interesting that on the CR website https://www.registrucentras.lt/p/1321 the service fees range from a few cents to a few euros. Meanwhile, the programming service that CR is ready to provide to Raimda auditas UAB is priced at 50 EUR/hour. It is also strange that the information provided in the e-mail received in February contradicts the information provided so far. We share some interesting accents of communication with CR:

  • CR customer service employees stated in writing and orally that there is no technical capability of providing this type of service (reporting on a unique code)
  • We asked several times by telephone about the possibility of compiling a report - all the time CR employees informed that such a possibility is not available
  • After submitting a written request and receiving a call from CR employees regarding the request, we received the same answer - CR does not have the capability to generate a non-standard scope report
  • In mid-February, the CR‘s Chief Data Analyst responded that the report could be generated by paying a solid amount for programming.

Do CR customer service employees, in fact, have no competence, as if they had agreed to repeat that the report we requested could not be drawn up? This question remains open. Only after getting in contact with the CR‘s Legal Department and the Press Department “could not” changed to “possible”. Surprisingly, such a seemingly elementary service is treated as non-standard in these times of the information technology boom. The only conclusion is that information technologies continue to be difficult to find in public institutions.

2nd March 2021
Daiva Žumbakienė

In the attachments:

  1. Inquiry submitted by Raimda auditas UAB to Centre of Registers on 27 December 2020.

 

[1] The solution to the situation is analogous when a unique code is assigned to several natural persons

[2] https://www.registrucentras.lt/naujienos/index.php?mod=news&act=view&id=40415

Idle time and average wage

The word “idle time” is a very common term these days. Accountants and ordinary employees are uncertain about how the unused leave allowance should be calculated in the event of redundancy. Compensation for unused leave is calculated in accordance with the provisions for calculating the average wage (AW). The purpose of this article is to draw attention to rarer cases.

The average salary is calculated[1] in accordance with the legal regulations - the Description of the Procedure for Calculating the Average Wage[2]. Often, even the accountant has a question: how to calculate compensation for unused leave in the event of dismissal if, say, the employee did not work during the idle time.

Final benefial owner - is it applicable only to the private sector or to the public sector as well?

Legal requirements for the prevention of money laundering are usually addressed ONLY to private businesses. Should the provisions of these legal requirements, namely the identification of final beneficial owner, really only apply to the private sector and not to the public? After all, it is a public secret that in all countries, not only in Lithuania, public sector procurements are carried out in accordance with the relevant provisions of the public procurement laws and millions, and often much more, are spent there.

Inventory of intangible assets or audit of information technology

The crux of the problem: the Government Resolution On the Approval of Inventory Rules (hereinafter - the Rules) states that in order to assess the de facto compliance of intangible assets (licenses, programs, etc.) with documents, an information technology audit should be performed, unfortunately this is not mentioned anywhere in the Rules.

Who is right: STI or SODRA?

The business needs to provide declarations and various forms to both State Tax Inspectorate (STI) and The State Social Insurance Fund Board (SODRA). For the accountant as well as the business, it is most important that the obligations are fulfilled properly. Usually, everyone tries to provide declarations and forms in good faith and in a timely manner. However, is that benevolence expressed by STI and SODRA? In my opinion, STI makes effort in some cases, while at the same situation SODRA takes a totally opposite position. 

The application of the provisions of the Second Book of the Civil Code, in the same situation, is interpreted differently by the STI and by SODRA. Looking from the side, it would seem that SODRA still lives in extremely large bureaucratic clutches, as if the clock was turned back several decades ago. But the time does not stand still, therefore should SODRA make a change?


 
 

Audit

We provide Audit of financial statements and audit related services (such as reviews, review engagements)

Accounting

We provide accounting services for Ltd (Limited liability company), Small partnership, Personal company, physical persons on a self-employment bases
 

Consultations

Tax consultations, consultations on accounting, legal (labor law) issues
Consultations on international double taxation agreements
Consultations on the International Financial Reporting Standards (IFRS)
Consultations in the transition from Lithuanian Business Accounting Standards (BAS) to IFRS

 
 
 
 
 
 
 
 
 


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Our team

UAB Raimda auditas
director Daiva Žumbakienė

  • member of ACCA since 2010
  • ACCA practising certificate
  • a graduate of Oxford Brookes University
  • a member of the Lithuanian Chamber of Auditors (LCA)
  • a member of the board of LCA
  • La member of the board of the Lithuanian Association of Accountants and Auditors (LAAA)
  • a member of working group of Accountancy Europe (AE) IFRS 9 Financial Instruments
  • Vilnius University
  • English, Russian, French

UAB Raimda auditas
auditor’s assistant Solveiga Mamavičienė

  • Aleksandras Stulginskis Agriculture Academy
  • Registered as the auditor’s assistant in the LCA
  • More than 30 years of work experience in the fields of taxation and accounting Work experience in the following areas: telecommunications, energy sector, trade, manufacturing, agriculture, etc.
  • Fluent in professional topics in Russian

UAB Raimda auditas
auditor’s assistant Monika Kvietkutė

  • Vytautas Magnus University
  • More than 10 years of experience in the fields of taxation and accounting
  • Work experience in the following areas: trade, production, healthcare, manufacturing, agriculture, etc.
  • Constantly improves profession qualifications in EU projects
  • Fluent in English, Russian and Italian

UAB Raimda auditas
auditor’s assistant Lina Urbonaitė

  • Kaunas University of Applied Sciences
  • Work experience in the following areas: production, trade, service, forestry, agriculture, etc.
  • Constantly improves profession qualification in EU projects.
  • Fluent in English

UAB Raimda auditas
auditor’s assistant Živilė Butkevičienė

  • Vytautas Magnus University
  • Kaunas University of Technology
  • Work experience in the following areas: production, services, support services
  • Excellent writing and speaking in professional English and Greek

UAB Raimda auditas
auditor’s assistant Laura Matulevičienė

  • Kaunas University of Technology
  • Work experience in the following areas: manufacturing, services, service sector, agriculture, etc.
  • Communicates in English and Russian


Contacts

Office address:
Karaliaus Mindaugo per. 68-11, Kaunas LT44351
Coordinates 54.885045 23.925614
Phone 8 37 206 980
Email info@raudit.lt
Company code 302509547
VAT code LT100005399614
Registration adress:
Dobilų g.8 Neveronių km. Kauno raj.sav. LT54478
A/S AB SEB bankas LT59 7044 0600 0753 1377

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