The Center for Freedom of Information published the 2024 annual "Black List", which includes the heads of departments that violated the constitutional right of people or organizations to receive information during 2024 by providing unreasonable or incomplete answers, illegal refusals or leaving information unanswered at all. requests to receive.
The center's message states:
"These agencies and officials violated the constitutional right of individuals or organizations to receive information during 2024 by providing unreasonable or incomplete responses, unlawful denials, or leaving requests for information unanswered.
During 2024, the Freedom of Information Center sent 250 requests for information, 225 or 90% of which received a timely response, 3.6% received a late response, and 2% received an incomplete response 1.6 percent of the requests received the status of "answer" and "silent rejection" each, and in the case of 1.2 percent of requests, the rejections were unjustified.
Minister of Foreign Affairs Ararat Mirzoyan
in 2024 On January 24, the Center for Freedom of Information sent a request to the Ministry of Foreign Affairs, asking to provide information about the specific position of the RA government on the issue of Artsakh in its foreign policy agenda, whether the right of self-determination of Artsakh Armenians and the security of the return of Artsakh Armenians to Artsakh are included in the document of negotiations with Azerbaijan. issues of guarantees. IAK asked to provide information about which issues and problems related to Artsakh and Artsakh Armenians are presented for primary discussion by the RA government in international platforms and in diplomatic relations with other states.
Samvel Ghukasyan, former head of Yerevan city center administrative district (April 2022-May 2024)
Armine Tangiyan, a resident of the city of Yerevan, applied to the Center for Freedom of Information, asking for assistance in obtaining information. The citizen sent a request for information to the Kentron administrative district in 2024. on February 22, requesting to provide information regarding the owner of the first and basement floors of building 31 Mashtots Street, Yerevan, "JESEN Voskevaz" LLC, but did not receive a proper answer. On March 20, the IAK sent a request with the same content to the Yerevan city center administrative district and received a rejection. According to the writing, "... information about the business owner cannot be provided, because according to Article 39 of the Law "On Fundamentals and Administration", only the participants of the given administrative proceedings have the right to get acquainted with the administration materials, while the mentioned Freedom of Information Center NGO is not a participant of the administrative proceedings"). IAK called the refusal unreasonable and sent a second request, in response to which the administrative district provided an already incomplete answer. As a result, although IAC finally received the required information, in order to get the answers to all the questions presented in the survey, it had to send four surveys instead of one.
Former Minister of Internal Affairs Vahe Ghazaryan (January 2023 - November 2024)
in 2024 On May 24, the Center for Freedom of Information sent a request to the Ministry of Internal Affairs, asking to provide copies of all sub-legislative acts deriving from the RA law "On the features of administrative proceedings in cases regarding violations of road traffic rules detected by video recording or photography devices". The IAC also requested to provide the list of police officials who have the right to access the video and photo storage and access the data provided by the last paragraph of Article 22 of the RA Law "On Police", the procedure for using the data, preserving and destroying the data, the videographer, the photographer, the list of technical means of video recording, a copy of the order of the head of the Authorized Body defining the range of officials making decisions on the use of mobile technical means. The Ministry of Internal Affairs refused to provide the requested information, stating that the legal act is not information. IAK called the refusal unreasonable and appealed, but the appeal remained unanswered.
Former mayor of Gyumri Vardges Samsonyan (November 2021-October 2024)
Lilit Aghekyan, a resident of Gyumri city, applied to the Center for Freedom of Information, asking for assistance in obtaining information. The citizen applied for information to the Gyumri municipality and did not receive a proper answer. On the advice of IAK, the citizen also sent a second request, but received the same response. On September 5, 2024, the IAK sent a request with the same content to the Gyumri municipality, but the center also received an unreasonable rejection. The municipality refused to provide a copy of the technical passport of Gyumri Ghandilyan 48a residential house and adjacent plot, referring to Article 8, Part 1, Part 2 of the RA Law "On Freedom of Information" and Article 3 of the RA Law "On Personal Data Protection" The norms referred to in clauses 1 of part 1 are not sufficient grounds for refusal.
In another case, in 2024 On September 17, in order to conduct a research on data protection and data security in Armenia, Freedom of Information Center researcher Gevorg Hayrapetyan sent a request for information to the Gyumri municipality, asking to provide information on whether the "Community Management Information System" is operating in the municipality, and if so, then by what document is it defined? Through the request, the applicant requested to provide other data related to the processing of residents' personal data. Gyumri municipality did not respond to the request. On October 4, 2024, researcher Gevorg Hayrapetyan sent a double request, which was also left unanswered by the municipality.
Yerevan Mayor Tigran Avinyan
in 2024 On September 17, Freedom of Information Center researcher Gevorg Hayrapetyan sent a request for information to the Yerevan Municipality in order to conduct research on data protection and data security in Armenia, asking to provide information on whether the "Community Management Information System" is operating in the municipality, and if so, then by what document is it defined? Through the request, the applicant requested to provide other data related to the processing of residents' personal data. The request remained unanswered, so the researcher sent a second request to the municipality. This time an incomplete answer was provided. provision of the information requested by one of the questions was refused, without indicating the legal basis (relevant law) of the refusal."
