#2026-016CNIL review expanding the “SI Honorabilité” background-check platform to disability, elder care, family carers, and adult protection
AI-generated summary for informational purposes only. Not legal advice. See the original source for the authoritative text.
This decision supports expanding France’s “SI Honorabilité” system so it can be used to check criminal-record restrictions for people working with disabled adults, older adults, family foster carers, and adults under legal protection. It means more professionals and volunteers in social and medico-social services will need to request an honorability certificate through the platform before they can work in covered roles. The CNIL accepts the new data collected as proportionate, but it flags several practical issues: the ministry must spell out how long B2 criminal-record query data is kept, the system should include statistical reporting, and access must stay limited to specifically authorized DGCS staff. It also warns that the digital application process must remain usable for people who struggle online, and it repeats its push for stronger security, including multi-factor authentication and better automatic monitoring of system logs.
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Key Changes
- Expands the SI Honorabilité platform to cover disability services, elder care, family foster carers, and adult legal protection roles
- Adds new data collection for work location and, in some cases, identity details for home-based professionals
- Keeps DGCS as the only intermediary for checks and calls for clearer retention rules, statistical reporting, and stronger security
Obligations
What this law requires
The Ministry must specify in the text the retention period for data relating to B2 criminal-record queries used in the SI Honorabilité system; the CNIL notes this period should be a maximum of six months.
The Ministry must add the statistical-purpose finality to the draft text for SI Honorabilité, covering pilotage of the attestation rollout and departmental child-protection policy monitoring.
Access to the FIJAISV and B2 checks, and to issuing honorability certificates for the handicap and older-adult sectors, must remain limited to agents individually designated and authorized by the Director General of the DGCS.
The SI Honorabilité portal for honorability requests should provide an effective access route for users who have difficulty with digital tools; assistance mechanisms must be capable of ensuring real access to the service for all applicants.
The Ministry should implement multi-factor authentication for the SI Honorabilité environment; the CNIL reiterates that two-step password-plus-email-code authentication is not equivalent to recommended MFA.