Concerns about possible data leak in Kringloopwijzer

According to LTO Melkveehouderij, the unrest could revolve around the sharing of data from dairy farmers. Data is the central issue at KLW, and is interesting for both dairy farming itself and the government. Nothing has been made public about the input of dairy farm managers in the KLW consultation with the government, because their input does not fall within the scope of the Open Government Act (WOO). 

Useful for containment sector
Contributions from civil servants of the Ministry of LVVN have been published. These show that these civil servants were mainly interested in KLW data that they could use to 'restrain' dairy farming.

Representatives of the dairy farming industry, who were (and are) involved from ZuivelNL, probably could not have done much about this, even if they had wanted to, because ZuivelNL has had a Public-Private Partnership (PPP) with the government since 2016 on the further development of the Kringloopwijzer, with LVVN paying for it.

PPP, where LVVN pays
This consultation includes civil servants from LNV, scientists from WUR, employees of ZuivelNL, representatives of accountancy organisations, financiers and managers from the dairy farming sector (but only from LTO and DDB, the NMV may join as an observer, but is not a PPS partner). This PPS is renewed every 3 years, while LVVN ensures that the bill is paid from the top sectors policy. The further development of the KLW is largely paid for from this, but undoubtedly also its management.

Via PPS and via ZuivelNL
This PPS steering group exists parallel to a separate working group of ZuivelNL for the KLW (and is now called the working group Instruments). ZuivelNL has full authority over this, but not over the PPS steering group. However, it is unclear what the responsibilities in the latter steering group exactly lie and what the powers are.
In 2021, the PPS steering group submitted a request to ZuivelNL to receive the dairy farming data. This was rejected, as is apparent from the published documents, but it has not been made clear whether this request was only about the legal transfer or a total refusal.

Nothing shared?
The LTO dairy farming sector assured in a newsletter sent last week that no data is shared with the central government by the steering group in which it is represented with the DDB at the PPS consultation. However, it seems illogical that the government does not know the data. The calculation core of the Kringloopwijzer is namely from Wageningen UR, which belongs to the government and whose employees who carry out assignments for the sector and also use the KLW data for this, also carry out assignments for LVVN. ZuivelNL also acknowledges that data is shared with the government, but according to a response from ZuivelNL this is only at meta-level, not individually. 

Gray data area
It would be good if it did not go any further, but there is always a grey area around data security. The hosting of the dairy data is in many cases with VAA in Rosmalen. Not only ZuivelNL stores data there, but also the partnership of dairy companies Partico does so. The hosting party itself is not allowed to do anything with the data, but it is striking that this party does advertise on LinkedIn with forecast models for the milk supply. Something seems wrong there.

Openness as a remedy
LTO Dairy Farming (and possibly other parties in the dairy industry) does not increase clarity by simply rejecting the issue the published documents. What could help is that she also releases her share in the PPS consultation. That space is there. Now the suggestion hangs over the market that the PPS consultation has been used by a part of the dairy farming sector as a channel to consult with the government about further development and/or shrinkage of the sector without anyone having to know about it.