Key Benefits:
National Computer and Liberties Commission,
Entering the Ministry of Labour, Employment, Vocational Training and Social Dialogue and the Ministry of Social Affairs, Health and Women's Rights of a request for an opinion on a draft decree authorising the creation of Processing of personal data for the implementation of the activity premium and carrying out various regulatory measures and involving, inter alia, the collection and processing of registration numbers of persons in the national directory Identification of natural persons;
In view of the Council's Convention 108 Europe for the protection of persons with regard to the automatic processing of personal data;
In view of Directive 95 /46/EC of the European Parliament and of the Council of 24 October 1995 on the protection of natural persons, The treatment of personal data and the free movement of such data;
Given the code of social security, in particular Title IV of its book VIII;
Given the code of social action and families;
Given the code of the Work;
Due to Act No. 2015-994 of 17 August 2015 on social dialogue and employment;
In view of Law n ° 51-711 of 7 June 1951 on the obligation, coordination and secrecy of statistics, in particular Article 7a;
In the light of the amended Act No. 78-17 of 6 January 1978 relating to computers, files and freedoms, In particular the provisions of 1 ° du I and of the 4 ° of II of Article 27;
Having regard to Decree No. 2005-1309 of 20 October 2005 as amended for the application of Act No. 78-17 of 6 January 1978 relating to computers, files and freedoms;
Vu The decrees Nos. XXX taken for the implementation of Act No. 2015-994 of 17 August 2015 establishing the Activity premium;
Having regard to the file and its supplements;
After hearing Ms. Laurence DUMONT, Commissioner, in her report and Mr. Jean-Alexandre SILVY, Commissioner of the Government, in his observations,
Emet the following opinion:
The National Commission on Informatics and Liberties was seized by the Ministry of Labour, Employment, Vocational Training and Social Dialogue and the Ministry of Social Affairs, Health and Women's Rights A request for an opinion on a draft decree authorising the creation of processing of personal data for the implementation of the activity premium and carrying out various regulatory measures.
Article 1 of the draft decree Specifies that: " The National Family Allowance Fund (CNAF) and the Caisse centrale de la mutualité sociale agricole (CCMSA) are allowed to create personal data processing, as well as family allowance funds (CFO) And the funds of the agricultural social mutuality (credit unions of the MSA), implement for the management and payment of the social benefit referred to as "the activity premium provided for in Article L. 841-1 of the Social Security Code"
Articles 57 to 62 of Act No. 2015-994 of 17 August 2015 on the social dialogue And employment, the activity premium is to reform the income of active solidarity (RSA) in its component Activity ", complementing the low wages, and the employment bonus (PPE), consisting of a tax credit.
The activity premium will replace, as of January 1, 2016, these two benefits deemed not to be effective by the debtor organizations Social benefits. It will be, as well as the other benefits, paid in arrears on 5 of each month. The first payments will be made on 5 February 2016.
This new benefit is codified in Articles L. 841-1 et seq. Of the Code of Social Action and Families and is intended to encourage workers with modest resources, Employed or self-employed, in the exercise or resumption of a professional activity and in support of their purchasing power.
Its allocation is subject to a condition of age, namely 18 years. Active young persons are eligible for the activity premium in accordance with the rules of common law, except for employed students and apprentices, for whom eligibility is subject to specific rules, namely to be able to justify A minimum amount (of remuneration).
According to the simulations carried out by the CNAF, and according to the rate of appeal selected, the number of households receiving the activity premium in a year would be 4 million, of which 700 000 to 1 1 million youth aged 18 to 25.
To the extent that these treatments They are intended to be implemented by legal persons governed by public law and relate to data which include the registration numbers of persons in the national directory for the identification of natural persons, The application of the provisions laid down in Article 27 (1) of Article 27 of the amended Act No. 78-17 of 6 January 1978 relating to computers, files and freedoms, which provide that the creation of the treatment must be made by decree in State Council taken after reasoned and published opinion of the committee.
Implementation of The activity premium involving the creation of a number of teleservices, it is also necessary to apply the provisions laid down in Article 27, paragraph 4, of the Act of 6 January 1978, as amended.
The proposed order is also intended to To constitute a single regulatory act within the meaning of Article 27 of the Act of 6 January 1978, as amended. As a result, compliance commitments will have to be addressed to the committee by each controller, prior to their implementation.
The creation of the activity premium implies adaptations of all treatments Implemented by the CNAF, the CCMSA and the organisations of their respective networks, and exchanges of information with their partners. The Committee notes that it will be informed of the changes to existing treatments and, where appropriate, requests for opinions on draft regulatory acts amending treatments requiring adaptations.
The Commission Notes that the examination of this request for an opinion is in line with the decrees Nos. XXX taken for the application of the Act of 17 August 2015 introducing the activity premium which specify the operating procedures of the activity premium and Draw the consequences of removing the door " Activity "
the purposes of processing and teleservices:
The treatment referred to the Commission for opinion, as specified in Article 1 of the draft decree, is intended to enable the CNAF, the CCMSA, and the CFOs and the Funds of the MSA to implement the activity premium and, to that end:
1 ° Activity premium estimate based on information provided by the applicant potential in a simulator;
2 ° With the collection, retention and control of the necessary information, the calculation of the Amount of the activity premium and its payment;
3 ° The individualised management of the relationship with the applicants and the beneficiaries and their information, by any means available to the bodies responsible for this mission;
4 ° The use Information necessary for the monitoring and processing of friendly procedures, Ex gratia and litigation;
5 ° The use of information necessary for the implementation of prevention and control actions against ' Mistakes, abuse and fraud " ;
6 ° The production of anonymous statistics for the purposes of evaluation, research and the conduct of public policy in social matters
7 ° Conducting surveys for the development of statistics, studies and research On the activity premium.
The Committee notes that the concepts of " Mistakes, abuse and fraud " The
considers that the distinction between these concepts should be specified in the European Parliament and in the European Parliament. Draft decree to strengthen the information of the persons concerned. In this respect, she points out that the assumptions made by the concepts of " Abuse " And " Fraud " In practice, questions the appropriateness of this distinction. It also considers that the Fault " Characterised by a lack of intention, more in one ' Error " And that this change should be made in the draft decree.
In the light of the responsibilities of the debtor organisations of the activity premium, the Commission considers that these purposes are determined, explicit and legitimate
The Committee also notes that the draft decree states in Article 3 that: In accordance with Article R. 846-1 of the Social Security Code, applicants and beneficiaries of the activity grant shall provide the information necessary for the examination of their situation using the telesservice provided for that purpose or, failing that, On their application, by depositing the form provided for this purpose with the agency responsible for serving the activity premium. "
With respect to the CNAF teleservices:
The CNAF implements various tele-services, namely:
-an activity premium request teleservice;
-a quarterly resource reporting service;
-a situation change report teleservice.
The Commission reports that the teleservice of Demand for the activity premium is part of an online declarative logic, on the website www.caf.fr. The data will be pre-filled and validated, if necessary after correction, by the applicant. In case of a positive result, this input will be completed on the display of the amount of the activity premium and the date of the payment.
will be affected by the activity premium request teleservice:
-the beneficiaries who are the beneficiaries of the RSA " Activity " As at 31 December 2015, eligible for the activity premium, these will be " Swapped " Automatically in the activity premium device as of January 1, 2016 and do not have to make an online request;
-the non-SARs of the RSA " Activity " And potentially eligible for the activity premium, which will be able to be informed of the opening of the request service and will be able to access it through their secure personal space. In this case, the request is pre-filled with data from their altenant folder;
-non-eligible first-time applicants eligible for the activity premium:
-some of them will have performed a simulation at the end of 2015 And part of their data will have been preserved to be " Preloaded " In their online application premium. At the end of their online application, they will be automatically registered and a provisional initial password, which they will be obliged to modify at their first login, will be transmitted to them and will give them access to their personal space;
-the Other first-time applicants, who will not have used the early simulator;
-people who are not eligible for the activity premium at the end of their application.
Quarterly Resource Reporting service a Vocation to allow the beneficiaries of the activity premium to declare Regularly their online resources for the relevant reference quarter. This telesservice is accessible to the tenants from their secure personal space " My account ", accessible from the dedicated website or mobile app.
The Commission notes that email awareness campaigns will be deployed to invite people to make an activity premium online. To report their resources on a quarterly basis and to inform them of their rights. In particular, with regard to the quarterly statement of resources, in addition to the use of e-mail messages, a reminder can be made to beneficiaries via SMS, as well as information injected into the mobile
. CNAF simulators:
In addition, the Commission notes that the CNAF will implement a temporary early simulator between November 2015 and early January 2016, as well as a permanent simulator, as soon as the request for information service is opened. The activity premium in January 2016. These simulators will be available on its website and, concerning the permanent simulator, also from the secure personal space " My Account " Of the tenants. The purpose of these simulators is to:
-to enable the public to know whether they are eligible for this new benefit and, if so, to have the indicative amount of the premium, without having to apply for CFOs;
- " Qualify " The situation of the person concerned (non-beneficiary tenant of RSA, tenant recipient of RSA, non-assignee or " First-initiator ") Before it makes an online request, on the basis of information already known by the CNAF.
The simulators require the user to reply to a sequence of questions and provide information concerning them Other members of the household.
The personal data provided during the simulation leading to a favourable outcome for the activity premium may be injected into the activity premium request teleservice and Be used if the request is made in the stride, and purged from the Simulator. On the other hand, if the simulation results in a negative result, the processing will end and no data will be stored in the simulator or injected into a base.
In the specific case of first-time applicants eligible for the activity premium, it They are offered to provide some information and to be contacted by e-mail in January 2016, as soon as the teleservice is opened.
The applicants who would like it, and who would connect to the teleservice as a result of a broadcast Emails carried out by the CNAF in January 2016, certain data entered by them at the time Their early simulation would be pre-loaded in the application, with the possibility of modifying and correcting them before validation.
With respect to the CCMSA's remote services and simulator:
The CCMSA has been proposing since November 1, 2015 Simulator or " Eligibility test ". More concretely, it will be a link on the website www.msa.fr, allowing users to be redirected to the CNAF's temporary early simulator. An adaptation of the CNAF simulator to the needs of the public of the CCMSA is being studied, but would only intervene, if necessary, from 1 January 2016.
The CCMSA will also make available to its members as from 1 January 2016, In the private space, accessible from their personal account on their website, the following services:
-a single service " Bonus of activity ", which will allow the user:
-to have an estimate of his right, based on a calculation made on the basis of the information declared by him and of the data already held by the CCMSA;
-to file his request for Activity premium;
-enter its resources at the request depot and during the quarterly review;
-a teleservice for declaring " Change in family or professional situation ", existing and already in production.
The Commission points out that the development of the dematerialisation of the services provided by the debtors of the activity premium must have The aim is to set up tools to simplify administrative procedures and improve relations with users. The implementation of the various teleservices must not, however, have the effect of excluding users who do not have internet access, in particular by providing an opportunity to take steps on the spot or via other channels Exchanges such as paper forms. In this respect, it observes, in the light of the additional elements transmitted to it, the mandatory character of the electronic address of the applicant for the activity premium, at the teleservice stage enabling the application to be carried
. The choice to impose the information on an e-mail address could be justified by a need to verify the reliability of the information relating to the applicants. However, it considers that another need should not lead to the exclusion of applicants who do not have or would not wish to have an e-mail address from the benefit of this
. The purposes pursued by these processing operations for the implementation of the activity premium and those requiring the implementation of the services of the CNAF and the CCMSA cited above are determined, explicit and legitimate
Processed data:
Article 2 of the draft decree submitted to the committee lists the data used by the treatments whose purposes are listed in Article 1.
These data are as follows:
I. -Data relating to the applicant or beneficiary of the activity premium and other members of his household:
1 ° Their credentials:
(a) The National Physical Person Identification (NIR) registration number or, for persons who are in the process of assigning a registration number to the national directory for the identification of natural persons, a number Wait ID (NIA);
b) Family name, use name, first name;
c) Gender;
d) Date and place of birth and, if applicable, date of death;
e) Nationality, if this information is required to apply Bilateral convention, or the quality of a national of a member country The European Economic Area, including France, or the Swiss Confederation, or a non-member country of the European Economic Area;
(f) Proof of identity or residence permit and information on the validity of This one;
g) For foreign-born persons, the data of filiation;
(h) For persons who have resided abroad, the date of entry into France;
i) For applicants and beneficiaries of the activity grant also alters Of the family branch of the general system, the tenant number.
2 ° Information relating to their dwelling place and contact details:
a) The mailing address of the applicant or beneficiary of the activity premium, that of the applicant's spouse, partner or partner with a PACS if different and that of the children and other members of the household;
b) The date of installation of the Applicant or beneficiary at the address mentioned in the a and the manner of occupancy (ownership, rental, colocation, under-leasing);
(c) The amount of rent, the repayment of the real estate loan or the indication of the occupation of the accommodation free of charge ;
d) The e-mail address of the applicant or beneficiary of the activity premium and Telephone numbers
3 ° Information relating to the family status of the applicant or beneficiary of the activity premium and its spouse, partner or ACAP partner on the date of application and during the preceding three months Review or revision of the entitlement to the activity premium:
a) Marital status (married, paced, single, separated, widow/widowed) and start date;
b) In the case of an ongoing pregnancy, the statement of pregnancy and the date of first prenatal examination;
c) Number of children or other Persons under the age of twenty-five dependants within the meaning of Article R. 842-3 of the Social Security Code and their dates of arrival and departure from the home.
4 ° Information relating to the professional situation of the applicant or beneficiary The activity premium, spouse, partner or partner with ACAP and PACS Children and other members of the household on the date of the application and during the three months preceding the examination or revision of the right to the activity premium.
5 ° Information relating to the resources of the applicant or beneficiary of the activity premium, of Spouse, partner or partner with ACAP and children and other dependants in the home:
a) Salaries, allowances (maternity, paternity, adoption, sickness), remuneration (traineeship of vocational training), income of non-employees, unemployment benefits, alimony, retirement pensions, annuities, collected during the three months Civilians prior to the review or revision of the law;
(b) Taxable professional income of non-employees in the penultimate year preceding the year in which entitlement to the allowance is reviewed or revised, or in the last year if they are Known;
(c) Taxable resources of the heritage The penultimate calendar year preceding the review or revision of the law.
6 ° Other information necessary for the processing of the activity premium and its payment:
a) An applicant's bank identification statement,
b) The applicant's social security plan (s), or beneficiary of the activity premium, spouse, partner or partner with ACAP and children or others Dependants Constituting the Home/Home;
c) In the case of the applicant's or beneficiary's hospitalization, start date and end date of hospitalization;
d) In the case of detention of the applicant or beneficiary or of his/her spouse, concubin or Partner with ACAP, start date and, if applicable, end of detention;
e) If applicable, the justification for the situation of refugees or stateless persons;
(f) In case of a stay outside France, the dates of entry and exit of the
. -Data on the management and monitoring of the activity premium, in particular information relating to the existence of an amicable resort or litigation relating to an activity grant application and the traceability data relating to access The salaries referred to in Article 1 by the agents of the bodies responsible for serving the activity premium.
As regards the collection of data of filiation for persons born abroad, the Committee notes that the latter must Have a residence permit authorizing work for at least five years, with Derogations for nationals of the European Union, in particular, under the provisions of 2 ° of Article L. 842-2 of the Social Security Code.
When asked about the nature of the information collected in order to establish the filiation of persons Foreign-born, the treatment officers indicate to the commission that they relate to the identity of the parents (surname and first name) of the applicants or beneficiaries born abroad and are present on the birth certificates of these Last.
This information is required by the debtor organizations in the The
considers that these data are adequate, relevant and not excessive in relation to the purposes for which they are used.
On the origin of the data and the methods of feeding the treatments:
The treatments implemented by the CNAF and the CCMSA for the management and payment of the activity premium are fed by:
-the data from the nominal social declaration created by Article L. 133-5-3 of the Social Security Code, where they are included;
-the useful information transmitted by the DGFIP and by any protective body The information provided by the applicant or the beneficiary of the activity grant,
is necessary for the examination of their situation.
These methods of feeding the Processing does not call a commission observation.
On the Recipients of data and authorised persons:
Article 4 of the draft decree examined by the committee specifies that they have access to the data referred to in Article 2, within the limits of their need to know, the officers of the CNAF, the CFOs and the CCMSA, whose missions justify it, Individually appointed and duly authorised by the director of their bodies.
As specified in this article of the draft decree, they are also addressed to the data of the treatments, in the strict limit of the information they have to Know in the light of their missions, the agents authorised by the competent authority:
-National Fund for Workers' Health Insurance (CNAMTS), for the detection of potential beneficiaries of complementary universal health insurance (CMU-C) and support for the acquisition of complementary Health (ACS);
-from the institution referred to in Article L. 5312-1 of the Labour Code, for the management of entries and deletions from the list of jobseekers;
-the services of the competent State, for their own evaluation work And their participation in the certification of state accounts;
- Bodies, local authorities and their groups, public institutions, services and enterprises serving social benefits or benefits and for which certain information relating to the bonus
decree further provides that, in accordance with the provisions of Article 7a of the Act of 7 June 1951, the statistical services of the Ministry responsible for employment, the ministry responsible for the action Ministry of Social Security and Social Security are recipients of the data Referred to in Article 2, with the exception of the names, names and day of birth of the persons and data provided for in the 6 ° of the I of the proposed order.
The Commission notes that these services will thus have access to the registration number in the directory National identification of natural persons (NIR) or, for persons pending the assignment of a registration number to the national directory for the identification of natural persons, to a waiting identification number (NIA). The Committee was informed that this access would enable the statistical services of the relevant ministries to conduct more timely qualitative or quantitative surveys of the beneficiaries of the activity premium, or to conduct investigations On a larger population, seeking to over-sample the beneficiaries of the activity premium. These surveys will be part of the programme of evaluation of the activity premium, the principle of which is introduced in Article 61 of Act No. 2015-994 of 17 August 2015 establishing the activity
. Remains very attentive to the risks to freedoms caused by the extensive use of a particularly significant national identifier such as the social security number. It therefore recommends the implementation of a secret key hash, since this measure would maintain traceability, while reducing the risks to individuals as a result of the particularly stable nature and
On the other hand, the Commission's attention was drawn to the fact that filiation data for foreign-born persons are not necessary for statistical services. It therefore considers that the last paragraph of Article 4 of the draft decree should be amended by adding this information to those not to be known of these services.
On this reserve, the Committee considers that these Addressees have a legitimate interest in accessing the data of this processing.
It recalls, for all intents and purposes, that the subcontractor of the CNAF involved in the dissemination of e-mails inviting the tenants to carry out The quarterly income tax return can only act on the instruction of the Which is not exempt from its obligation to ensure compliance with the security measures imposed on it by Article 34 of the amended Act of 6 January 1978. The subcontractor must also present sufficient safeguards to ensure the implementation of the security measures, and the contract between the parties must include an indication of the obligations of the subcontractor in respect of the Personal data security
On data retention time:
The draft decree states that the data referred to in Article 2 shall be kept for a maximum period of six years following the year of the application for the activity premium or the end of the relationship with the beneficiary of the premium, or Until the intervention of a final decision in the event of a dispute.
It has been indicated to the committee that the choice of this six-year period for the retention of data is justified in the light of the provisions of Article L. 122-3 of the Code of Social security, according to which the accounting officers of a social security organisation May be subject to personal and financial liability for a period of six years. More specifically, it is expected that " The first act of the implementation of liability shall not take place beyond 31 December of the sixth year following the accounting year in question '. The accounting officers of the social security agencies are responsible for the benefits paid. The retention of information for six years must therefore provide a justification for the benefit assumptions that would not be made.
The draft decree also provides for the identification data of the Agents who have accessed the processing data are kept for a maximum period of one year after they are connected to the processing.
In order to meet the purpose mentioned in Article 1 (5), namely the use of the information necessary to The implementation of measures to prevent and combat misconduct, abuse and Fraud, the data can be kept, and linked to an anonymous number, in a separate logical environment, separate from the processing allowing the management of the activity premium.
The Committee observes that the dossier submitted in addition to the The request for an opinion indicates that the CCMSA retains the data injected into the system for five years, in accordance with the provisions of Article 2224 of the Civil Code, which states: Personal or transferable securities shall be prescribed by five years from the day on which the holder of a right has known or should have known the facts enabling him to exercise it. "
If the draft decree identifies only the duration of the Nevertheless, the Committee considers that the accuracy of this retention period for data injected into the CCMSA system for a period of five years in the draft decree would improve the information provided by the
It recalls that personal data, in application of the The provisions of Article 6 of the Act of 6 January 1978, as amended, may be kept in a form which permits the identification of the persons concerned only for a period not exceeding the duration necessary for the purposes for which the The data are collected and processed.
As a result, it is essential for the activity premium debtors to ensure that personal data collected and processed through the processing in question are not Not kept beyond the durations necessary for the fulfilment of the purposes Referred to in Article 1 of the draft decree.
In addition, in the context of the administration telesservices, information received at a distance may be stored only the time necessary for the transmission to the service concerned without To create a new database. It therefore invites the activity premium debtors to keep the data only as long as necessary for the transmission of data to the business applicators.
For all practical purposes, the committee specifies that the data At the expiration of these periods, must be deleted in a secure or permanently archived manner, under conditions defined in accordance with the provisions of the Heritage Code relating to the archiving obligations of the Public sector information.
On information and access rights, Rectification and opposition of persons:
Article 6 of the draft decree states that the persons concerned by the treatment examined by the committee are informed, in accordance with Article 32 of the law of 6 January 1978, as amended, by all The appropriate means, the purpose of the processing, the identity of the person responsible and the categories of recipients of the data. They are also informed that, in the event of a refusal on their part to disclose their personal data necessary for processing, their right to the bonus of activity cannot be appraised and that they cannot then claim it
The persons to whom the data referred to in Article 2 relate are informed of the procedures for exercising their rights of access and rectification of data concerning them by information appearing on the websites Of the CNAF and the MSA, as well as in the form CERFA and the teleservice of Request for an activity premium.
The dossier submitted in addition to the request for an opinion also indicates that a dissemination of the information will take place by means of the notifications addressed to the persons by their CIF, at the opening and at the Termination of the law.
Applicants and beneficiaries of the activity grant may exercise their rights of access and rectification of the data provided for in Articles 39 and 40 of Law n ° 78-17 of 6 January 1978, as amended, with the Director of The organization responsible for serving the activity premium to which they are attached.
The Agents of the bodies responsible for serving the activity premium are informed of the procedures for exercising their right of access to data concerning them by their employer.
Finally, the Commission takes note of the fact that the draft decree excludes the exercise of the Right of opposition for legitimate reasons pursuant to the provisions of Article 38, paragraph 3, of the King of 6 January 1978 amended which states that this right shall not apply " Where the processing complies with a legal obligation or where the application of those provisions has been excluded by an express provision of the act authorising the processing. '.
The Committee considers that these methods of information and exercise The rights of access and rectification of persons are satisfactory.
As regards the manner in which these rights are exercised, the Commission considers that it would be appropriate, in so far as the debtors of the activity premium are involved in A process of dematerialization of their services, to give priority to Opportunity for applicants and recipients of the activity premium, to exercise their rights through dematerialized channels, in particular from the proposed services.
On Data Security and Action Traceability:
The Server Hosting the personal data files is located in a secure room with controlled access. In addition, the technical premises are accessible only to the authorized staff of the National Informatics Centre, by security zones, according to the rights at its disposal. The security of these zones is ensured through the reading of magnetic badges.
Network architectures are equipped with traditional firewalls and proxy servers. A high availability architecture has been implemented for these platforms. These devices, including workstations, are automatically updated on a daily basis.
The application is not accessible via the internet or via an extranet. The application does not use Internet mail.
Only individuals from organizations and members of the Management Central department are directly empowered, by their Director, to access the information.
Access to Information systems are strictly reserved for internal users through a private enterprise network. Access to each server and hosted applications is subject to an authentication mechanism based on the couple " Identity/password " With strict renewal and structure rules.
Application managers, in conjunction with the administrator, associate clearances profiles with identified user groups. By platform, a central security administrator himself performs the setting of these clearances, or delegates these tasks to the regional administrators according to the hierarchy of clearance checks requested. This central administrator has the means of audit and control to verify the good quality of all this information. There are safeguards to guard against a manipulation error in the assignment of profiles.
The security measures described by the processors are in compliance with the security requirement of section 34 of the Act. January 1978 amended.
The Commission points out, however, that this obligation requires the updating of security measures in relation to the regular reassessment of risks.
The Commission also recalls that, in accordance with the Decree n ° 2010-112 of 2 February 2010 for the implementation of the Articles 9, 10 and 12 of Ordinance No. 2005-1516 of 8 December 2005 on electronic exchanges between users and the administrative authorities and between administrative authorities, the proposed teleservices must comply with the Requirements in the general security repository (RGS).
On the provisions amending the Code of Social Action and Families and the Labour Code:
The Committee notes that the provisions amending the Code of Social Action and Families and the Labour Code introduced in Article 8 of the draft decree do not require any special comment on its part, since it is merely a matter of Minor editorial changes.
The President,
I. Falque-Pierrotin
