The Metamorphosis Foundation for Internet and Society supports the process of adopting a comprehensive and long-term National Strategy for ICT 2021-2025 with an accompanying Action Plan, which will provide more efficient identification of priority areas in the ICT sector and will prepare the Republic of North Macedonia (RnM) for a comprehensive and agile digital future. The main focus of the Strategy and Action Plan is to face the challenges imposed by the growing need for connectivity in society, strengthen competitiveness and enable the daily lives of citizens and businesses to be smarter.

Based on our previous experiences and specialist expertise developed through projects and initiatives such as National Strategy for Development of Information Society (2004-2005), Safe on the Internet (2007-present), Free Culture – Creative Commons, Open Access to Academic Content and the European Network Komunija (2007-present), the research Computer use in education (2010), Open educational resources (2012-present), Critical thinking for mediawise citizens – Crithink (2018-present), Increasing civic engagement in the digital agenda – ICEDA (2020-present) and a number of other previous and current activities, the team of the Metamorphosis Foundation for Internet and Society in cooperation and consultation with external experts made brief thematic analyzes of the draft National Strategy for ICT 2021-2025 with accompanying Action Plan, from several key aspects, including:


We provide the short thematic analysis below. If you wish to download them to your digital device, you can do so by clicking on the topics above.


Recommendations for the draft National ICT Strategy 2021-2025 and the accompanying Action Plan related to the right to privacy

(Recommendations are given in the context of the implementation of the Law on Personal Data Protection (Official Gazette of RNM no. 42/20) and the GDPR-General Data Protection Regulation 2016/679)


  • In the process of strengthening the IT capacities of the institutions, apart from the IT professionals, a key human resource that needs to be seriously planned is the Personal Data Protection Officer. The role of the Personal Data Protection Officer is elevated to a higher level where expertise and independence come first. To ensure efficiency in the fulfillment of the obligations, the institutions are obliged to ensure that the Personal Data Protection Officer is adequately and timely involved in all issues related to personal data protection and support them in performing the tasks, providing them with all necessary resources and access to personal data and processing operations.
  • When defining the infrastructure of the central secure data center, especially in the part of downloading all applications of all ministries, agencies, institutions, universities and hospitals, it should be borne in mind that many of the existing applications do not have the principles of personal data Every institution that has an application through which personal data are processed should analyze it, evaluate it and obligatorily harmonize its functionalities with the Law on Personal Data Protection before submitting it to the data center at all. Non-compliant collections of personal data, applications and other e-tools can only further weaken the system of security and protection of personal data, and thus jeopardize the security of the central data center itself.
  • There is an essential difference between the e-services of the institutions which are an alternative way of obtaining the service (and not an additional service that the citizens could not otherwise receive) and those services that are only available to the citizens electronically (and the citizens could not otherwise receive). This is a key issue that must be taken into account in centralizing the delivery of e-services. For services that are only accessible to citizens electronically, the principles of “only once” and channel selection will have to be revised and their application re-evaluated.
  • The adoption of a communication strategy and the planning of promotional activities must not be forced before it is previously checked whether the existing e-services are supported by Privacy Policies, whether all the principles for protection of privacy in the provision of e-service are respected and whether the institutions have defined ways and channels through which citizens can request the exercise of their right to privacy.
  • The government should ensure that the work of each ministry, body, institution and public enterprise that offers e-services is harmonized with the Law on Personal Data Protection. This is especially significant because the principle of Security by design refers to new services, tools, applications, and not to the existing ones that are expected to be redefined following the principles of the Law on Personal Data Protection.
  • The government should ensure that every institution offering e-services respects the principles of “legality, fairness and transparency”; “limitation of objectives”; “minimum data volume”; “accuracy”; “limitation of the storage period”; “integrity and confidentiality” and “accountability”.
  • In the context of establishing a Center for Safer Internet for Children, the Government should support the transposition process of Directive (EU) 2016/680 of the European Parliament and the Council for the Protection of Individuals about the processing of personal data by the competent authorities to prevent, investigate, detect or prosecute criminal offences or for carrying out criminal sanctions and for the free movement of this data which ensures the use of technological means by the police which are not invasive to privacy. This directive is the second key regulation, in addition to the General Data Protection Regulation (GDPR) in the field of personal data protection which should be part of the national legislation.
  • When creating new e-services or tools, especially for services for the provision of which there is no legally prescribed procedure (such as, for example, StopKorona,, MOJ DDV), the Government should support the institutions in the process of conducting analysis and privacy impact assessment as a mandatory first step before deciding to create the e-service or tool itself.
  • The relationship between the Government and other entities should be clearly defined and it should be known which entity at any time appears in the role of a personal data processor, the user of personal data or a third party. This relationship must be regulated by special agreements between the institutions, which refer exclusively to the provision of measures for personal data protection.
  • The Government should adopt a methodology for detection, reporting and remediation of security incidents related to breaches of personal data security of citizens when using e-services or tools. In doing so, re-access to the data subject to the incident should be provided without exception.
  • The Agency for Personal Data Protection Agency (PDPA) should be actively involved in the implementation of the ICT strategy. Apart from being a resource center of knowledge and practices, PDPA will have to give its opinion, approval and guidance in several activities, so their involvement is essential to ensure a process that will support the implementation of the Law on Personal Data Protection in every aspect.



Recommendations for the draft National ICT Strategy 2021-2025 and the accompanying Action Plan related to accessibility by persons with disabilities


In the period from July 1 to July 12, 2021, a detailed analysis of the accessibility by persons with disabilities was conducted in the implementation of the strategies covered in the Draft National Strategy for ICT 2021-2025 and the Draft Action Plan of the National Strategy for ICT 2021-2025 by a person with a physical disability. The analysis lasted 8 working days where all the elements contained in the Draft National Strategy for ICT 2021-2025 and the Draft Action Plan of the National Strategy for ICT 2021-2025 were included.

The analysis covered several types of disabilities present in the population of the Republic of North Macedonia, including persons with partially or completely impaired hearing, persons with partially or completely impaired vision and persons with physical or mental disabilities.

During the analysis, several questions and remarks arose about the needs and opportunities of people with disabilities and addressing their specific needs.

In the part of “Strengthening ICT curricula in the education system”, the Government of the Republic of North Macedonia (RNM) claims that it will direct its efforts to develop ICT events and career orientation fairs to attract as many students in the ICT sector as possible. However, the question arises whether the Government takes into account people with disabilities in the effort to attract students to the ICT sector?

If we take into account the current digital education system in the ICT sector, it can be said that it is not accessible enough for most people with disabilities and is a kind of discrimination because it deprives these people of the opportunity for progress and digitalization, especially in this sector.

To achieve the goal of the Government of RNM and to include people with disabilities in the strategy for attracting more students in the ICT sector, it is necessary to make fundamental changes in the digitalization of the education system for people with different types of disabilities to be able to independently access all digital tools, regardless of their specific needs.

In this regard, the initiative to “provide easy access to services for all categories of users, including the elderly and people with disabilities, as well as ongoing verification of compliance of the design of the public website with the guidelines and adaptive technologies of the “Web Accessibility Initiative” is in a good direction. Consequently, it is recommended to review the existing websites of state institutions and the e-services/digital tools they offer in all areas, as well as their adaptation to the needs of people with disabilities to actively enable their informed participation in social processes.

The previously mentioned issue was not explained at all in any aspect of the educational digitalization for persons with disabilities in the Draft National Strategy for ICT 2021-2025 and the Draft Action Plan of the National Strategy for ICT 2021-2025.

The next question that arose during the analysis was directed to the “Digital Agency of North Macedonia”. The Government of RNM announces that it will establish, through an official legal procedure, a central Digital Agency, which will be a new opportunity for job creation.

If the agency forms a highly qualified team from the private and public sector and offers a modern, attractive work environment and experience, the question is whether it will be adapted and made available to people with disabilities that would be qualified for a certain position in the Agency.

During the analysis, it was noticed that the Draft Strategy does not emphasize the possibility of implementing inclusiveness in the workplace where people with different types of disabilities would have the same opportunities for advancement and independent work as their co-workers.

After performing this analysis, it was determined that the needs of persons with disabilities are not sufficiently covered in the Draft National Strategy for ICT 2021-2025 and the Draft Action Plan of the National Strategy for ICT 2021-2025 of the Republic of North Macedonia. This leads to systematic discrimination and division and runs counter to the mutual principles and goals of the Government of the RNM.



Recommendations for the draft National ICT Strategy 2021-2025 and the accompanying Action Plan related to digital inclusion


(Recommendations are given based on the Digital Agenda Observatory – Report Country Report and Roadmap for Digital Agenda advancement in North Macedonia from 2020 and 2021, and in the context of digital inclusion)


  • Although efforts are made to place all e-services from the institutions on the National e-Services Portal (Portal), certain e-services are provided independently by the institutions. It is recommended that all state e-services offered by the institutions at the national and local level, be centralized in one place, i.e. be offered through the Portal. Furthermore, within the Portal, it is advisable to provide a unified database with all data on e-services (information on the number of registered users segregated by legal entities and individuals, information on the most requested or most used services by citizens and companies, information on the number of delivered e-services, data resulting from measuring customer satisfaction, etc.). This database can be further used by institutions, civil society, the business community, etc. in terms of decision making, creating in-depth research and strategies, as well as creating innovative IT solutions.
  • The DANM (Digital Agency of Northern Macedonia) initiative will gradually introduce end-user services to major life events by integrating service delivery from different data owners, with the help of the existing Interoperability Framework. By the end of 2025, at least five such services will be operational. This is a big step in a good direction. At the same time, it is recommended to establish a transition plan, i.e. full digitalization of precisely defined services, with precisely defined deadlines in which the counter option for that service will be gradually limited, towards its complete abolition. At the same time, it is necessary to give intensive support to the citizens in that direction.
  • When introducing innovations, it is recommended that the institutions strive to ensure their sustainability and practicality after a certain period, due to which it is necessary to provide proper care for their continuous functionality. In that direction, it is necessary to strengthen the cooperation with the civil sector in the field of “Research and Innovation”.
  • Regarding the awareness building for the e-Government and e-services portal, and the commitment “by 2022 a coherent communication strategy and action plan should be adopted, to increase the visibility of the e-services available to the citizens”, it is recommended that the civil sector, which is a bridge between the citizens and the institutions, and that best understands the needs of the citizens, be included in the creation of these strategic documents. Furthermore, it is recommended that the implementation of the strategy be supported by a strong marketing team to make it easier to raise collective awareness of the Portal and thus reduce scepticism about e-services. In the same direction, it is recommended that the Government appoint a spokesperson who will regularly report on progress in the implementation of the Digital Agenda (DA) and related activities, and who will be recognized by the citizens in that context. This is also necessary to raise public awareness of the benefits of DA, as well as to bring it closer to the citizens. In that direction, it is necessary to promote the activities and cooperation under ISA2, i.e. the results of the implementation of DA to be directly related to the future membership of the Republic of North Macedonia in the European Union (EU).
  • The commitment to strengthen digital skills in public spaces by providing access to ICT (connectivity, equipment, but also human resources to support the citizens) in public infrastructure and space is also underway and is moving in a positive direction. This is achieved through developing the role of public libraries to Improve digital inclusion, managing 18 internet clubs across the country and exploring the role that the future network will have for one point of service, as well as developing ICT services in public spaces so that every citizen of RNM can have available tools and ways to upgrade their digital skills. Concerning the provision of digital devices for vulnerable categories of citizens and the collection and renewal of digital distribution devices to persons eligible for such assistance, it is advisable to consult initiatives that performed this role voluntarily during the COVID-19 pandemic. (e.g. Donate a computer) in terms of sharing experiences and synergy opportunities.
  • Regarding the bridging of the digital gap that exists between a part of the population and the society that already lives in the digital world as well as those who do not have any digital equipment, it is recommended to ensure the capacity building of civil society organizations and media for informing and educating citizens about the Digital Agenda and its benefits. CSOs, as the main points that work directly with the citizens and are already familiar with their needs, can further play the role of multipliers where they, with institutional and financial support from the institutions, will be able to spread digital literacy among the population and work directly with citizens to develop their digital skills.
  • Within the development of digital skills of all citizens, it is necessary to plan the development of an educational program at several levels (primary, secondary, advanced) that would communicate appropriately to the age, mental capacity and expertise of citizens in all areas. In addition to developing digital skills through formal education (preschool, school, high school, faculty education), it is advisable to create lifelong learning programs to include citizens who are not part of formal education.

We emphasize that digital inclusion must evolve along with the evolution of new technologies, which also means investing in reducing and removing historical, institutional and structural barriers to accessing and using technologies.

The Metamorphosis Foundation for Internet and Society continues to work actively in the field of promotion of human rights and social accountability which are part of the strategic commitments of the Foundation, and also continues to analyze the draft National Strategy for ICT 2021-2025 with accompanying Action Plan on at least one other topic – gender equality.