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NLMonitoring participation hours of status holders: transparent and GDPR-proof
Municipalities monitor the participation hours of status holders most reliably by recording the hours at the time and place of the activity, linking them to the PIP and the hour norm, and settling data sharing with partner organizations in a processing agreement up front.
The administration then holds up for DUO, and you see who is falling behind while there is still time to act, not at the end of the quarter.
What a municipality has to track
Since the Civic Integration Act 2021 (Wet inburgering 2021), municipalities direct the integration process. In the personal plan for integration and participation (PIP) you record, per person, which learning route they follow and which agreements apply. The municipality has to track progress to establish whether the PIP has been met, as the Divosa Q&A on the Z-route puts it (Divosa is the Dutch association of municipal social-services directors).
The hour norm is sharpest in the Z-route, the self-reliance route. For asylum status holders in that route the norm is 1,600 hours: at least 800 hours of Dutch language and knowledge of Dutch society (KNM), and 800 hours of activation and participation. The participation statement programme (PVT) and the labour market and participation module (MAP) count toward those participation hours, according to DUO's conditions for the Z-route. The MAP also has a requirement of its own: 8 themes and at least 40 hours of practical experience, completed within the three-year integration term (Divosa on the MAP).
Not every hour counts. Divosa names three conditions for the participation component: the activity takes place in a Dutch-speaking environment, not in isolation, and requires active effort from the participant. Paid work therefore counts, provided it meets those conditions. Guidance and progress meetings about the PIP do not count, because they are an activity of the municipality, not of the newcomer. The Z-route ends with a mandatory final interview, which only takes place once the hour requirement has been met. Two weeks after you enter the date of that interview in the DUO portal, the certificate becomes available for download.
So the registration is not a side task. Without complete hours you cannot schedule the final interview, you cannot show that someone has met the integration obligation, and you only find out afterwards who fell behind.
Four ways to register participation hours
In practice we see four variants, from loose lists to registration at the source. The differences are mainly in who registers, how quickly the municipality sees it, and how much privacy work it creates.
| Criterion | Lists and email per provider | The municipality's case management system | Generic time-tracking app | Participation platform with registration at the source |
|---|---|---|---|---|
| Who registers | The provider, afterwards | The case manager, based on what providers send in | The provider or the participant, per activity | The participant, on location (for example with a QR code), confirmed by the provider |
| When the municipality sees it | Monthly or quarterly | After the municipality processes it | On export or sync | In real time |
| Error-proneness | High: retyping, duplicate hours, forgotten activities | Medium: depends on what comes in | Low for the hours, but the link to the PIP is often missing | Low: one record per activity, linked to the person and the hour norm |
| Insight for the newcomer | None | Only through the case manager | Sometimes | Yes, in their own app |
| GDPR work | A lot: every email is a data exchange | Limited, inside the municipality's own system | Processing agreement with the vendor | Processing agreement with the vendor, role-based access for partner organizations |
| Fits | A handful of participants | Municipalities that process everything themselves | Organizations that only want to count hours | Municipalities working with several partner organizations that want real-time insight |
In the same guide, Divosa recommends a user-friendly digital registration system because it reduces manual errors and keeps data storage consistent (Zorg voor nauwkeurige administratie en inzicht in participatie-uren, in Dutch).
How to set up the process
1. Define what counts and who is responsible
Start with a list of activities per partner organization, noting whether each meets Divosa's three conditions. Agree who registers the hours and who confirms them. Put those agreements in the contract or subsidy decision with the organization, so nobody has to reconstruct anything afterwards.
2. Register at the source, not at the end of the quarter
The closer the registration is to the activity, the more reliable the hours. A participant who checks in at the start of a language café produces a better record than a coordinator going through attendance sheets three months later. Check weekly for missing records instead of checking everything once a quarter.
3. Link the hours to the PIP and the hour norm
A bare hour counter says little. What you need per newcomer is: hours achieved against the norm in the PIP, the status of PVT and MAP, and a signal when someone is falling behind. That is the dashboard case managers work with, and it is also the basis for your reporting to DUO.
4. Give the newcomer insight into their own progress
Divosa points out that seeing your own hours and progress builds confidence and motivation, and that a visual overview helps participants who can barely read. An app in which someone sees their own progress is the simplest form of this. The overview of activities also feeds into a CV.
5. Plan fixed progress moments and arrange the reporting to DUO
Divosa recommends monthly contact moments to discuss obstacles. Those meetings do not count as participation hours, but they are the moment to adjust course. The formal registration of the PVT and the completion of the route runs through DUO's integration portal (Portaal Inburgering); the day-to-day hour administration stays in your own system.
GDPR-proof registration: what is and is not allowed
The Civic Integration Act 2021 provides the legal basis for processing progress data: article 35 governs which data course providers supply to municipalities. Where the act does not cover a situation, municipalities fall back on the GDPR principles of legal basis, purpose limitation and proportionality. The privacy questions in the Divosa Q&A work this out in detail (in Dutch); the GDPR basics are explained on the Dutch government's privacy pages.
- Determine each party's role. Providers of the MAP, the PVT and social guidance are processors: sign a processing agreement with all of them, whether you subsidize or procure them. Language providers are independent controllers, as is the COA; no processing agreement is needed there.
- Be careful with the citizen service number (BSN). Municipalities, language providers and course institutions may use the BSN for their task. Other local providers may not. A registration system in which partner organizations record hours without seeing the BSN solves this.
- Record only what is needed for progress. No medical data, no suspicions, no free-text notes about someone's private situation. Hours, activity, date and provider are enough.
- Replace email traffic with role-based access. Secure email is, according to Divosa, an acceptable way to exchange data, but every email is a separate processing operation. A system in which a partner organization's coordinator only sees their own participants is easier to account for.
- Carry out a DPIA for your own tasks. The VNG, the association of Dutch municipalities, offers a standard processing agreement and a DPIA template. No processing agreement is needed with DUO: DUO is a processor for the Minister of Social Affairs, not for municipalities.
Where Taaly fits
Taaly is an example of the fourth column in the table. With Taaly's hour registration, the newcomer scans a QR code at the partner organization's activity. The municipality sees the participation hours in real time, without after-the-fact reporting, and the partner organization only registers its own participants. Twelve municipalities register hours through Taaly; in the first municipal pilot this meant 80% less administration. Hour registration is part of a broader platform: newcomers practice Dutch with an AI language coach and with 4,200+ volunteer taalcoaches, and find activities in their own municipality through Taaly Meedoen. The impact results are externally validated with the OpenEmbassy Integratie Impact Framework, and Divosa has named Taaly as an example of AI in civic integration.
Want to see what real-time insight into participation hours looks like for your municipality? Plan a demo.
Frequently asked questions
How many participation hours does a status holder in the Z-route have to complete?
For asylum status holders in the Z-route the norm is 1,600 hours: at least 800 hours of Dutch language and KNM and 800 hours of activation and participation. The PVT and the MAP count toward those participation hours. For family migrants the norm is 800 hours of language and KNM, plus the PVT and the MAP. This is stated in the Divosa Q&A on the Z-route and in DUO's conditions.
Do working hours count as participation hours?
Yes. Hours of paid work count toward the participation component, provided the work takes place in a Dutch-speaking environment and not in isolation. Guidance and progress meetings about the PIP do not count, because they are an activity of the municipality.
Does a municipality need a processing agreement with every organization that registers participation hours?
With providers of the MAP, the PVT and social guidance, yes: they are processors for the municipality. Language providers and the COA are independent controllers, so no processing agreement is signed with them. Nor with DUO, which is a processor for the Minister of Social Affairs.
May partner organizations use a newcomer's citizen service number (BSN)?
Only municipalities, language providers and course institutions may use the BSN for their task. Other local providers may not. So choose a way of registering in which partner organizations record hours without seeing the BSN.
How can municipalities effectively monitor and register the social participation of status holders?
Register the hours at the time of the activity, by the participant or the provider, in one digital system. Link those hours per newcomer to the norm in the PIP and to the status of PVT and MAP, so you see who is falling behind. Give the newcomer insight into their own progress and plan monthly progress meetings. Settle the roles and processing agreements with partner organizations in advance.
