“The real innovation is openess”

Why do questions around data protection and data management hold quite so much weight in integration work?

Boris Kühn: As a colleague of mine once neatly summarized: When people emigrate, they come with their entire lives – and encounter all the different institutions and authorities in Germany. That’s why integration is a cross-sectional matter. Immigrants also have far more contact with the authorities than those without a background of migration. As such, integration often only serves to catalyze the issues that, in principle, affect everyone – such as how authorities share data. And as people who are new to Germany generally struggle to understand the complex bureaucratic processes, not least because of the potential language barrier, it is particularly difficult, but also particularly important, to boost their informational self-determination, that is to say their control over their personal data.

And after all, there is no one integration authority in Germany, but rather a whole number of different agencies are involved in this process.

Kühn: Exactly. There are federally funded institutions, advice centers in the individual German states, and local case management. Not to mention job centers and civil society actors. The starting point for our research project was the fact that the living situation of immigrants as well as their sensitive data are being newly recorded in many of these places: What’s your name? Where are you from? Could you show me your identity papers, are they up to date?

Danielle Gluns: Both administrative staff and immigrants described the need to enter the same data multiple times as annoying and inefficient. But the consequences can actually be quite severe if, for example, incorrect data is stored somewhere, with those affected either unaware or unable to correct it because each institution has its own system with no technical interfaces. It can also happen that different advisory institutions take the same people in different directions, for instance if a job center prioritizes finding employment quickly, while another side is focused on language courses.

What’s interesting about your study is that you bring two perspectives together: that of the administration with those of the users, that is to say immigrants. How exactly did you go about this?

Gluns: We started from the assumption that innovative solutions for contemporary data management in the field of integration already exist in Germany. To gain an overview, we searched for them throughout Germany using, among other things, the distribution list from the German Federal Government Commissioner for Migration, Refugees and Integration. The feedback came as a surprise: Rather than reports of solutions, we were met with problems and failed projects. That’s why we conducted a range of background discussions and semi-structured interviews, both with employees of administrations and advice centers as well as immigrants, in order to identify the key stumbling blocks before developing ideas on how we could successfully implement a next step together with data protection experts.

Do you see any parallels here with the fight against the pandemic since 2020, where the German administrative apparatus often proved inefficient? I’m thinking of fax machines in health authority offices.

Kühn: Actually, I primarily work in administration, and I certainly haven’t come across any instances of people working with fax machines. Digitalization is making progress – instead, when it comes to integration, we have to contend with a pillarization of the system, with the fact that different institutions are failing to share often even the minimum of information with one another. In turn, that then complicates data collection, data management, and dealing with data protection.

Would it simplify things to set up a central database for the key points of integration?

Kühn: It goes without saying that there are pros and cons. But from the study, we concluded that this wouldn’t be for the best. In fact, many of the practitioners confirmed this, saying that, as an administration, they don’t want a system of “transparent” migrants.

Gluns: The Central Register of Foreign Nationals is a nationwide register which records almost all persons with foreign citizenship. A wide variety of institutions have automatic access to the register, including the police and immigration authorities among others. Our study found it’s not expedient to have a central register with sensitive data for the integration sector, which in any case is often more focused on social work. I wouldn’t want my health, bank, or registration data and so on to all be in one place, for there to be people who know everything about me. So why would immigrants want that either?

For many immigrants, German authorities mainly mean waiting and then submitting the same documents for new forms.

In the study, you write that there should be more appreciation for the “spirit of data protection”. What exactly do you mean by that?

Kühn: All too often, data protection is only implemented in a formal, bureaucratic way. You get your signatures, but the data collection system and even official structures as a whole are really quite opaque for many immigrants. None of our interviewees even knew the Central Register for Foreign Nationals actually existed, for instance. If you don’t know there’s a database, how can you control how accurate the data is or what your rights to manage it are.

Gluns: Everyone is always clicking on something online, signing their consent without reading through the scope of data collection or possible disclosure. So in a way, it’s a general problem with data protection, but when it comes to integration work, the language barrier is an added hurdle. When immigrants are in contact with the authorities, they often don’t even realize they have a choice whether to sign a piece of paper or not.

Data collection

High complexity

This chart shows how many different agencies immigrants come into contact with in Germany.

Institutions which routinely collect immigrants’ data

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In your study, you recommend among other things multilingual forms and standardized processes created for local authorities by a higher body. Aren’t there any promising digital solutions there?

Gluns: Actually, the real problems rarely lie in a lack of technologies. In the study, we use the example of how a German municipality regulates admissions to a language course with a cloud-based solution. This means that documents, such as certificates, no longer have to be carried around by hand and that different stakeholders have access to them. A number of departments had to be brought on board, meaning introducing this system was time-consuming and expensive. What’s more, the employee in charge added that the whole thing only kept running because he kept reminding those involved to please use the cloud.

Kühn: In terms of the tech involved, it’s not actually that innovative. And of all the municipalities we surveyed, there was only one that uses a model like it. The real innovation is helping the administrative units out of their silo to search for a common solution.

“Things become more tricky when each authority insists on its own database.”

Quote fromDanielle Gluns, political scientist

So this isn’t so much a case of technical challenges, as of having to rethink administrative structures?

Gluns: Many computer scientists would argue that the technical issues are all easily solvable. But things become more tricky when each authority insists on its own database and legal hurdles crop up in establishing access rights for external bodies. We’ve also found that technical projects often indicate that the underlying structures are overly complex in parts.

Kühn: When it comes to integration, we need to view processes holistically: Where does something add to the workload, when is it beneficial? For the administration, for external advice centers, which are often publicly funded, and for immigrants. What we need is a broad understanding of digitalization: not the one-to-one transfer of potentially inefficient or opaque processes into the digital realm, but a real critique of processes that are then adapted for a new age. At this point, the needs of integration, an already cross-cutting topic, go hand in hand with the concept of a broad-based digitalization.

Three impact-focused solutions according to the “Connected Data, Connected Authorities?” study:

1. Rethinking that first contact with immigrants

Many immigrants have no idea that specific advice services even exist, or only learn about them late in the process. One option for establishing contact is to write to all new immigrants by mail. However, data protection law is unclear as to whether or not the unsolicited advertising of these services is actually allowed. If integration policy is serious about securing a comprehensive range of advisory services for new immigrants, the option to establish (postal) contact needs to be enshrined in law. It would also be vital to send invitations in the respective language of origin.

In an additional step, it would be important to consider how initial contact via messenger services, voice messages or social media could serve as a low-threshold and personal option for establishing contact. However, there’s no doubt that for these types of contact, requesting this data from the immigration services without consent would be pretty objectionable under data protection law. Here, the most likely intermediary is the registration office: When immigrants present themselves here, they could be asked whether and which forms of contact are preferable.

2. New systems need new structures

Data management and data linkage primarily become a visible issue where municipal case management comes into the picture, which in turn adds another layer of responsibility. If each local authority maintains its own database, a move (or even, in the case of refugees, an accommodation transfer) means a completely blank slate in the management and re-recording of all information, as well as a not infrequent loss of data.

Conversely, a standardized documentation system for all state-funded advice/case management centers would enable immigrants to take their data with them and seamlessly link it to their new advice centers. It’s clear that a great deal of resources could be saved if the software for documentation were made available by the federal states. However, it is vital that it’s left up to the immigrants on a voluntary basis whether or not they want to release their case documentation at their new place of residence – especially when it comes to passing on sensitive data or social work assessments.

3. Cooperation ahead of data sharing

Job centers, migration advice services, and local authorities sometimes work with the same people on similar issues, even if their legal mandate and self-conceptualization differ significantly. Not only is similar data collected across all institutions, skills assessments are also made and resumes developed. Even where a standardized database might not be the best option (see above), contradictory multiple consultations should still be avoided. Thus far, however, the quality of cooperation has all too often depended on the individuals involved.

 If we really want to encourage cooperation in the long term, it needs to be anchored at all relevant levels. At federal and individual state level, the legal and structural framework to support effective cooperation should be mandatory. At local level, this should be carried through into reality, for example for the concept of integration. In everyday life, regulations then need to be shared across all rungs of the ladder, including, crucially, administrative officers. The result should be a solid foundation of trust – which should also lay the groundwork for establishing data sharing.

Boris Kühn

He serves as the integration officer for the city of Mössingen in Baden-Württemberg as his primary occupation and is the study’s lead author.

Dr. Danielle Gluns

She is the head of the Research and Transfer Office for Migration Policy at the Institute for Social Sciences at the University of Hildesheim. A political scientist, she aims to promote exchange between research and practice in the field of migration policy.