This is a report of the explicit interpretation of the Dutch Aliens Act using the Calculemus method and the FLINT language. The method has been used before to make normative interpretations of regulations that form the basis for specific services to be delivered by governmental agencies and of legal cases. In this paper, the authors make an interpretation of an entire act, the Aliens Act. We give an overview of methodical choices that enable the analyses of extensive sources of norms, and report on the results of the analysis.
Reduce the complexity of processes and systems.
Build a system that is flexible and agile in response to changes in sources of norms.
Build a system that is supporting professional employees and is not perceived as a straitjacket. This resulted in several publications [7][13]. More recently INDiGO was used as a study case for a legal thesis on agile law making [14] (in Dutch).
Though INDiGO is doing fine as the information system for the IND, the ambition to build a system that is flexible and agile in response to changes in sources of norms is not fully achieved. At the same time, the need for flexibility and agility in relation to changes in sources of norms, traceability of the origins of norms is the system, and accountability on the compliancy of the system have become more important. The Dutch national government aims to have all public services to be available digitally. Furthermore, there is a debate going on requiring comprehensible explanation for all (automatic) decisions taken by administrative authorities. In co-operation with the Dutch Tax and Custom Administration (DCTA) the Leibniz Institute and the PNA group, the IND has searched for adequate solutions [5][14].
This paper is about the legal engineering aspects of INDiGO. We show an example of the explicit interpretation of the Dutch Aliens Act that aims to: 1. 2. 3. 4.
Make explicit interpretations of sources of norms that can be used in multidisciplinary teams consisting of lawyers, policy advisors, administrative workers and knowledge engineers. Make comprehensive, high-level interpretations of sizable amounts of sources of norms.
Enable a modular approach that allows adding detailed interpretation at a later time or adding links to interpretation of other sources of norms.
Enable structured debate on disagreements on interpretations of sources of norms and the application thereof in specific cases.
In this paper, we will discuss the first three aims. For more on structured debate on disagreements, see [3].
In Section 2, we will give a short overview of the results of early work in our quest for explicit interpretations of sources of norms and its theoretical basis. In Section 3, we will give a short introduction of the Calculemus method and the FLINT language for the explicit interpretation of sources of norms. In Section 4, we will present the results of the analysis of the generative norms in the Dutch Aliens Act. In Section 5, we will discuss results and future work. 2
In the development of INDiGO the acquiring and modelling of legal knowledge was a bottleneck. Legal experts and knowledge engineers had to work together to make sound models. However, while the legal experts could not see how a piece of text was not sufficient to be machine interpreted, the semantic engineers could not understand the interpretations of the legal experts. Knowledge engineers proposed a method that interprets norms as descriptions of behavior that is either allowed or forbidden [13]. This is essentially a deontic perspective on norms.
The approach succeeded in so far, that using this conceptualization the rule-base of INDiGO was created, that functions reasonably well. The goal of creating a single-source-ofknowledge on norms and rules, however, was not achieved. In our opinion this has two main causes: 1. 2.
The pursuit of completeness of the legal framework.
The choice for a deontic approach.
By striving to analyze 500+ laws and regulations in order to create a complete normative knowledge base, an impossible task was created. A modular approach that starts with a high-level interpretation of the core of the sources that regulate the work of the IND, would have been better [14]. In this paper we present such an approach.
The choice for a deontic approach neglects the importance of the regulation of the power to act. Power is a under specified concept in AI and Law [16].
In 1931 Kocourek [12] stated that there are different opinions on the number of fundamental normative relations, but that there was nobody that believed that there are more than four. People who follow the deontic approach believe that the fundamental legal relation is the claim-duty relation. This means, that in their opinion all normative positions and relations can be expressed using deontic concepts, e.g. Herrestad [10]. Kocourek himself believed that there are two fundamental normative relations: the claim-duty relation and the power-liability relation. According to Kocourek, Hohfeld is the most important proponent of four fundamental normative relations: claim-duty relation, powerliability relation, liberty-no claim relation, and immunity-disability relations [11]. In practice, there is little difference between the position that there are two or four fundamental normative relations. There is not much difference to claiming a libertynoclaim relation is fundamental, or that it is the same as an absent claim-duty relation. Therefore, we work with a model that is based on two fundamental normative relations.
In Section 3 we will present an approach that interprets sources of norms from an action perspective. We will do so by introducing the Calculemus method for building explicit representations of normative relations, and the FLINT language to express these representations.
For more on the theoretical base of FLINT, see [4].
In the last years we have been developing a method that aims to make interpretations of sources of norms that can be used: 1.
to make specifications for decisions being taken by machines and people in administrative organizations, to support the grounding of decisions made in courts, and to support the implementation and evaluation of policies in large organizations.
This work has resulted in a method to address questions related to norms between people and in organizations [1][2][3][4]. The goal of this method is to create a method for the interpretation of written or spoken sources of norms in natural language, resulting in specifications for normative multiagent systems that can be used by humans and machines.
For the explicit interpretation of sources of norms, we are developing the Formal Language for the INTerpretation of sources of norms (FLINT). This is a now semi-formal language that is evolved from working on real-life cases. The language consists of three frames: act frames, duty frames and fact frames.
The Act Frame is used to describe normative actions performed by an actor that results in normative changes addressed to an agent that is either receiving the results or is an interested party. This frame is called an act frame, because it describes all the aspects of the function that changes a state due to a normative action performed by an agent. We make a distinction between the action of the agent and all that is necessary to achieve an effect, i.e. a transition to another normative position. The act frame is presented in Table 1.
Act frame Action Actor Object Recipient / Interested Party Precondition Creating postcondition Terminating postcondition References to sources <<name of the act frame>> Action that causes the transition of an object Agent role that is allowed to perform action The object acted upon Agent role having a normative relation with the actor concerning his action Set of conditions that must be met to allow the action of the actor Facts or normative relations created by action of the actor Facts or normative relations terminated by action of the actor Reference to the source of the act type, including information on version
The act consists of the action of actor upon an object that is which is submitted to a transition because of that action. The act is valid if it is performed in a state that meets a precondition. If the action is performed and the precondition is met, the action will result in normative facts, and/or normative relations being either created or terminated. The act type frame describes a power-liability relation in which the actor holds a power to perform a certain action with a functional effect that comes to existence if the action is valid, i.e. if the precondition is met. The interested party holds a liability related to the action of the actor.
The act frame is a concept that exist only in institutional reality. The act frame and all its components are constituted by giving additional meaning to events in social reality by qualifying components of these events as components of the act frame, because the component in reality corresponds with the representations of these components in institutional reality. If the act frame is complete a representation is made that can be used to recognize acts in. As a result, institutional reality does not have a procedural perspective. The act in reality has a procedural perspective, for the act frame time is only relevant to determine the time interval in which sources of norms and/or the interpretation thereof and the time that events in reality are qualified as corresponding to components of the act frame.
The result of an acts frames can be either the creation or
termination of a fact (or multiple facts) that are created because of
the transition of the object1 (
The Duty Frame , see Table 2, represents deontic normative relations and consists of a duty, or obligation, that is in effect the state in which an institutional act that ought to be performed in the future, or ought to have been performed in the past in case of a violation of the duty.
Duty frame Duty holder Claimant Creating institutional act Enforcing institutional act Terminating institutional act References to sources <expression of the duty (future act)> Agent role holding the duty Agent role holding the claim The normative act(s) that creates the claim-duty relation The normative act(s)that the claimant can use to enforce the satisfaction of the duty in case the duty holder renounces a duty The normative act(s) that satisfies the claimduty relation (effectively terminating it) References to fragments of sources of norms for all frame elements, including information on version
One or more creating act frame(s) that can create the duty, enforcing act frame(s) that can be used to enforce the satisfaction of the duty in case the duty holder renounces his duty, and terminating (or satisfying) act frame(s) that effectively terminates the claim-duty relation the duty frame is an expression of.
In case a duty holder is of the opinion that he does not have a duty, he can claim a privilege or liberty towards the claimant, using an appropriate act frame. The claimant and the duty holder now have a conflict on the question whether a claim-duty relation exists, or not. The argument usually will be about the question whether the normative act that created the duty was valid, or whether or not the normative act that was supposed to terminate the duty was valid. Since this question is about the presence or absence of a claim-duty relation there is no need for a separate frame for liberty-no claim relations.
Fact frame Function
The third frame of the FLINT language concerns the Fact Frame. The fact frame can be used to make detailed statements on the precondition of an act. The precondition consists of a function of institutional facts connected by Boolean or arithmetic operators. Every fact in the function of a fact frame, can be the subject of a new fact frame. The level of detail that is pursued depends on the purpose of the analysis. The fact frame is presented in Table 3. 4
In 2018 a FLINT analysis was made concerning the relevant regulations for students and highly skilled workers that want to reside in the Netherlands, using the Calculemus method. Relevant sources of norms were collected, and explicit interpretations were made using the FLINT language. The experiment showed that it was possible to make a modular analysis of specific tasks of the IND using a middle-out approach, thus solving the gridlock caused by striving to completeness that was one of the causes for the unsuccessful attempt to create a single point of truth on normative knowledge for the IND during the development of INDiGO.
The results of this experiment also showed that the core concepts in the INDiGO information system, e.g. qualifications, criteria and evidence, did not, or no longer, reflect the specifications of sources of norms. Since the start of the INDiGO program, the original model, based on qualifications (rights that people want to qualify for), criteria (that should be met in order to be fit to qualify for a qualification), and evidence (with which one can sufficiently proof that a criterium is met) were contaminated because practical solutions were chosen to solve urgent requests of users of the systems. The architectural principles of the original system, as described in [7] were not properly guarded.
The analysis of the sources of norms for specific products, lead to the conclusion that there was a need for administrative specifications that combine a normative perspective with the practical perspective of administrators of the Alien Act. The 1 The object itself can be seen as a fact in the role of the object of action. For example: if an application for a permit is positively decided upon, it results in the creation of a permit, and the termination of the application, because it is not desirable to take a new decision on the application before withdrawing the first one. Unfortunately, this prototype was never taken in production. For the purpose of this paper the decomposition of the Aliens Act was done by hand. De Maat’s did experiment with several methods for the interpretation of norms, but did not come to a satisfying method for the interpretation of sources of norms in natural language.
Valid since (yyyymmdd) 20010401 20010401 20010401 20130601 20010401 20130601 question at hand, was whether it is possible to use the Calculemus method and the FLINT language to analyze larger amounts of sources of norms, without getting trapped by the quest of completeness. In legal analysis there is always the risk to get lost in exotic details, or possible exceptions: very interesting from a legal perspective, but irrelevant from an administrative perspective. We tried to bypass this trap by limiting the analysis to acts, i.e. act frames, that are grounded in the Aliens Act. The ratio of this choice is that by looking for act frames, we would be able to address all causes for the generation of new facts and new normative relations. The generation of normative facts or relation always requires an act.
The Dutch Aliens Act is one of the two main acts that is administrated by the IND.2 The Aliens Act regulates more then 80% of the work done by the IND. The question we want to answer using the Calculemus method is: “What Act Frames Can Be Retrieved from the Aliens Act?”
In order to answer that question, we have taken 5 steps:
Choose a way to split up the Aliens Act into separate containers of knowledge.
Classify constituents of the Aliens Act that contain act frames. Make classes of act frames that are found in the Aliens Act. Assign act frames to the IND.
Make guidelines for elaborating pre- and postconditions.
In April 2001 the first version of the Aliens Act came into effect. Since than numerous changes have been made to the original text. Every change was separately published by the Dutch government. The versions of the Aliens Act on the web [8] (in Dutch) is an aggregation of the original text and the official publication of all changes to the Aliens Act. For this paper the version that was valid starting July 28, 2018 was used. The full text of the law was divided into clauses, subordinate clauses, and components of enumerations. The English translation of the Dutch legislation in this paper are unofficial translations by the authors. The English designations used are based on the guidelines of the European Union [6]. The reason for decomposing the text of the law, is to make a set of components that are minimal meaningful units.
In Table 4 we show an example is for the decomposition of
Article 14 (
Art. 14
(
Art. 14
(
Art. 14
(
Art. 14
(
Art. 14
(
Art. 14
(
The Aliens Act consists of 1.387 components, of which 1.370 constitute the body of the law. The body of the law consists of 274 structural components, i.e. titles of chapters, divisions, sections, and titles of articles, leaving 1.096 components that contain sources of norms related to immigration policies. 4.2
An act frame is a classification for a clause, or a combination of clauses, describing a normative act: an action, performed by an actor, on an object, while a precondition is met, with a result and an interested party. So, the question is, which clauses of the Alien Act can be interpreted as being part of an act frame?
Usually a sentence in a source of norm, e.g. the Aliens Act,
that can be interpreted as an act frame, contains an action, an actor
and the object that is acted upon. Though, not always in the same
clause. In Table 4 you can see that the main clause of Article 14
(
The interpretation of the Aliens Act using act frames is done by selecting clauses that contain an action. A preliminary name for the act frame is given to the clause. Then, the source text is examined in order to find the actor, the object and the interested party of the act frame at hand. The exact words from sources of norms are used to express components of the act frame and to adjust the name of the act frame, if necessary. The precondition and postcondition (results) of the act frame are left open for further interpretation at a later time. These parts of the act frame are more complex because precondition and postcondition may be a composition of multiple components from multiple sources.
There are three main groups of act frames we found in the
Aliens Act. The first group concerns act frames that create
additional rules, e.g. the creation of rules by order in council, e.g.
in Article 2a (
a. further rules are laid down regarding natural persons and organizations that can act as sponsors;
The second group concerns acts that are providing authorities
to the Minister of Justice and Security, or to officials that act in
his name, e.g. Article 2c (
a. to grant, reject or disregard the application for recognition as sponsor,
The third group concerns act frames that give authorities to
individuals that are an interested party in relation to the Aliens
Act, e.g. Article 3 (
A decision to refuse entry to the Netherlands, that has already been taken, will lapse as from the time at which the alien indicates that he wishes to submit an application as referred to in the third Paragraph.
Here an alien is given the power to lapse a decision to refuse
the entry to the Netherlands by applying for temporary asylum
residence permit, i.e. the application mentioned in Art. 3 (
Of the 1.096 clauses of the body of the Aliens Act 250
contained one or more act frames. A clause can be the source of
multiple act frames when a clause contains multiple actions, e.g.
the clauses in Article 14 (
In the Aliens Act we found a maximum of four act frames in one clause. In total, we found a total 428 act frames in the Aliens Act. 4.3
The act frames in the Aliens Act can be divided in multiple categories. Table 5 gives an overview of the number of items for every constituting element.
Object Interested Party
In order to focus on the act frames for which the IND is responsible, we zoom in on the actors for whom a role is laid down in the Aliens Act, see Table 6. The actor charged with most of the acts described in the Alien Act, is the Minister of Justice and Security. These acts include the acts performed by the IND in name of the Minister of Justice and Security. The Dutch Government is involved in slightly less different acts. It concerns the authority to make additional rules by or pursuant to order in council on a large array of specific issues.
Minister of Justice and Security Government Official Charged with Border Control Official Charged with the Supervision of Aliens District Court Alien Carrier Administrative Authorities Administrative Law Division of the Council of State Chief of Police Officer in Command of the Royal Netherlands Marechaussee Sponsor (of the Alien)
Number of Acts
Officials charged with border control and supervision are mentioned separately because they not only take decisions in writing in name of the Minister of Justice and Security but are also authorized to use physical force for all kinds of acts, including imprisonment. The Commander of the Marechaussee is in charge of border control, the Chief of Police in charge of the supervision of aliens. The District Court is responsible for deciding on legal conflicts related to the Aliens Act. The administrative law division of the Council of State is responsible for the administration of appeals. Carriers responsible for illegally transporting people into the country can be forced to transport people to a place outside the Netherlands free of charge. Aliens and sponsors can perform acts related to their procedures to gain rights regulated by the Aliens Act. 4.4
The Minister of Justice and Security is responsible for tasks he performs personally, but also for a wide array of tasks carried out in his name by officials. The tasks of the IND are amongst these.
Of the 178 tasks assigned to the Minister, 106 are assigned to the IND. These tasks can be divided into 5 main categories:
Residence permits and recognized sponsorship Proof of lawful residence Deadlines for taking decisions Collecting and using biometrical data
Data and Knowledge Management
The result of this exercise is a complete set of actions the IND can perform based on the Aliens Act, divided in groups related to specific tasks and products. In Section 4.5 we show how the preand postconditions of act frames are constructed.
4.4.1 Residence permits and recognized sponsorship. The category residence permits and recognized sponsorship contains the core task of the IND. It contains 83 act frames concerning 45 objects. The IND administers the providing of four types of residence permits4:
Provisional residence permit (7 objects, 15 act frames) Regular residence permits (12 objects, 25 act frames) Residence permits based on European legislation (3 objects, 5 act frames) Asylum residence permits (11 objects, 21 act frames) Return visa (6 objects, 10 act frames).
The provisional residence permit is more like a visa than a residence permit. It is a visa to enter the Netherlands for people that apply for a regular residence permit. The regular residence permit is a residence permit that assigned for other reasons than for the purpose to give asylum. Regular residence permits are granted for specific purposes, e.g. family life, work or study.
In this paper, we will discuss the acts related to the granting, rejecting and disregarding of regular residence permits. The other categories are administered using technically comparable act frame, although there are considerable differences from a legal perspective. We will address these differences at another paper.
4.4.2 Proof of lawful residence. The IND is obliged to provide lawful residing aliens with a document or a written statement that proves lawful residence. For this task there are 5 objects and 5 act frames because for this category the only action is: to provide.
4.4.3 Deadlines for taking decisions. The Aliens Act requires the IND to decide on application within a limited period of time. There are separate time limits for every category of applications. Also, for all categories there are rules that regulate the possibility to extend the deadline for a decision. After the related act frames where extracted from the Aliens Act, we noticed the IND information architecture did not include decisions to extend the term available for deciding on application. Where the IND intends to use rule-based decisions for all tasks its primary process, decisions for extending deadlines were, until now, never seen as separate decisions. There are 10 different objects, 9 of which are 4 Permits for long-term residents of the European Union are, strictly speaking, a separate category, because they are based on European regulations. But for the purpose of this paper, they are included in the category regular residents permits. related to extending deadlines for taking decisions, and the other one related to making the decision known to interested parties.
4.4.4 Collecting and using biometrical data. The IND collects fingerprints and facial images of aliens for identification purposes. There are separate act frames for requesting biometrical data, collecting it, providing it to other agencies, receiving it from other agencies, and for comparing the fingerprints of aliens with fingerprints stored in a document of an administration. There are 6 objects and 6 act frames in this category.
4.4.5 Data and knowledge management. The Aliens Act describes how the IND ought to process personal data. The IND can designate administrations acquiring data concerning aliens and their legal procedures. There are act frames for requesting and acquiring data. There is an act frame for maintaining an aliens administration. And there are act frames for attaching written documents to applications. There are 6 objects and 6 act frames in this category. 4.5
Determining the pre- and postconditions of an act frame is not a straight-forward procedure. While the other elements of the act frame are singular concepts. The act frame can only concern one action and has one actor. However, the pre- and postcondition of an act frame may consist of complex statements. We will show some examples of complex preconditions and the use of fact frames for expressing the details of a complex precondition. The postcondition consists of one or more elements that are created or terminated if an act is valid.
We start with the representation of the act frame representing the rejection of an application to grant a temporary regular residence permit, see Table 7. We do so, because the Aliens Act contains specific grounds for rejecting an application to grant a temporary regular residence permit, or to disregard it, but not for granting it. The rules for granting an application must be derived from the inability to reject or disregard it.
Art. 66a (
Act frame Action Actor Object Creating postcondition Terminating postcondition References to sources
OR
[alien has pronouncement of undesirability]
OR NOT [application contains purpose of
residence]
OR NOT [alien has a provisional temporary
residence permit]
OR NOT [alien has a valid border-crossing
document]
OR NOT [interested party has sufficient,
independent, long-term means of support]
OR
[alien constitutes a threat to public order or
national security]
OR NOT [alien is willing to cooperate in a
medical examination of a disease designated by
the Public Health Act or to undergo medical
treatment for such a disease]
OR
[alien has performed any work in violation of
the Aliens Labor Act]
OR NOT [alien meets the restriction related to
the purpose of residence]
OR NOT [alien has sufficient knowledge of the
Dutch language and Dutch society]
OR
[alien has provided incorrect data or has
withheld data]
OR NOT [alien has only resided in the
Netherlands on the basis of Article 8 Aliens
Act]
OR NOT [sponsor has submitted a statement
for the purpose of the intended residence of the
alien]
)
AND NOT [adverse consequences of a decision
may not be disproportionate to the purposes to
be served by the decision]
[decision to reject application to provide a
temporary regular residence permit]
[application to provide a temporary regular
residence permit]
Art. 14 (
The next eleven possible grounds for rejecting a residence
permit can be found in art. 16 (
The last condition, i.e. that a decision may not have adverse
consequences that are disproportionate to the purposes to be
served by the decision, is not to found in the Aliens Act, it is a
general condition for decisions to be taken by administrative
authorities laid down in the General Administrative Law Act
(GALA) [9]. GALA provides a framework for Dutch
administrative acts. In this paper, we will not go into the details of
this matter. The fact that the result of the granting, rejecting or
disregarding of an application for a temporary regular residence
permit is a decision, is a result of the definition of the concept
‘application’ as the request by an interested party to take a
decision (art. 1:3 (
Disregarding of the application to provide a temporary regular
residence permit, see Table 8, is a rather simple act frame, it can
only be done on the ground that fees due for the settlement of to
grant a temporary regular residence permit have not been paid
(art. 24 (
This leaves the granting of a temporary regular residence
permit, see Table 9. Art. 26 (
Art. 26 (
The other elements in the precondition —that an alien that is
granted a temporary regular residence permit may not have a
travel ban or have been signaled for the purpose of refusing entry,
or have been pronounced undesirable based on art. 67 (
The postcondition of the granting of a permit has more
elements than the rejecting or disregarding of it. Apart from the
creation of decision to grant an application for the provision of a
temporary regular residence permit and the termination of the
application to provide one, several duties are created. The duties
follow from art. 14 (
Fact frame
Function
Fact frame
Function
[regular residence permit is granted from the
day on which the alien has demonstrated that he
meets all conditions]
[alien has demonstrated that he meets all
conditions of the regular residence permit]
AND
[day on which alien has demonstrated he meets
all the conditions for a regular residence permit]
AND
NOT [day on which alien has demonstrated he
meets all the conditions for a regular residence
permit lies before the day the application was
submitted]
Article 26 (
Article 26 Paragraph 1 Aliens Act
The fact [regular residence permit is granted from the day on
which the alien has demonstrated that he meets all conditions], see
Table 10, is based on Art. 26 (
[alien meets the conditions to provide a temporary regular residence permit] [application contains purpose of residence] AND [alien has a provisional temporary residence permit] AND [alien has a valid border-crossing document] AND [interested party has sufficient, independent, long-term means of support] AND NOT [alien constitutes a threat to public order or national security] AND [alien is willing to cooperate in a medical examination of a disease designated by the Public Health Act or to undergo medical treatment for such a disease] AND [alien has not performed any work in violation of the Aliens Labor Act] AND [alien meets the restriction related to the purpose of residence] AND [alien has sufficient knowledge of the Dutch language and Dutch society] AND NOT [alien has provided incorrect data or has withheld data] AND [alien has only resided in the Netherlands on the basis of Article 8 Aliens Act] AND [sponsor has submitted a statement for the purpose of the intended residence of the alien] AND [fees due for the settlement of to grant a temporary regular residence permit have been paid]
Article 26 Paragraph 1 Aliens Act
First we split the fact in three, resulting in the fact [alien has demonstrated that he meets all conditions of the regular residence permit], the fact [day on which alien has demonstrated he meets all the conditions for a regular residence permit], and [day on which alien has demonstrated he meets all the conditions for a regular residence permit lies before the day the application was submitted]. The fact [alien has demonstrated that he meets all conditions of the regular residence permit] is then elaborated in Table 11. The other two facts need an arithmetic function to determine whether they are true or false.
In Art. 106a (
The Boolean function that makes the fact [alien meets the conditions to provide a temporary regular residence permit] true consists of the combination of the precondition of rejecting the application and disregarding it, see Table 12.
The duty to grant a temporary regular residence permit under restrictions is created by granting the permit. Enforcing of the duty is possible by submitting a letter of objection. The duty can be fulfilled or terminated by a whole set of acts that are described in the Aliens Decree, an Order in Council that contains the majority of the rules that can be made based on act frames in the Aliens Act. For every restriction there is a separate act frame, with a specific precondition and a specific result. There are more than hundred separate restrictions, two of them are shown in Table 13.
Duty frame Duty holder Claimant Creating institutional act Enforcing institutional act Terminating institutional act
The determining of the period of validity of the residence permit is done in a comparable way. The rules for determining the period of validity of a regular residence permit are laid down in the Aliens Regulation, a regulation that contains regulations that are created by the Minister of Justice and Security pursuant to an order in council made on the basis of an act as described in the Aliens Act.
The last remaining duty is the duty provide the alien with a document proving lawful residence. There are five types of documents, document I is the type of document that is given to aliens with a temporary regular residence permit. The permit contains personal data of the alien, the restriction under which the permit is valid, and the period of validity. 5
This paper gives an overview of the application of a method for the interpretation of sources of norms to interpret the Aliens Act, and to make administrative specifications of tasks that are the responsibility of the IND. A first validation of these results has been made by a lawyer and a knowledge engineer working for the IND. In the next months there will be more extensive validations. The IND is about to decide whether to permanently use the presented method for making normative specifications.
The IND is about to decide what method to use to make traceable specifications for all tasks, products and processes administrated by the IND. Suitable alternative methods that can be used on industrial scale have not been found yet.
Results on the mapping of normative concepts on the information architecture are only preliminary. However, the FLINT representation is well received by experts in all relevant disciplines because:
They are perceived not to be merely technical but based on sources of norms.
The extensive references to sources provides insight in relations between information concepts, that cannot be (easily) found within the current information system systems, nor their architecture.
The modular approach, starting with a high-level interpretation that enables validating comprehensiveness, combined with the possibility to go into any level of detail, where necessary.
Further debate and validation of the results presented in this paper, may result in changes in the interpretation. It is one of the purposes of this method to clarify chosen interpretations and support argumentation about what is the ‘right’ interpretation [2][3]. We will report on the outcome of this process, and on possible modifications of the method resulting from it.
The analysis of the entire Aliens Act was performed by one single person within one month. This shows that a high-level analysis of the sources relevant to a complex governmental agency could be done in a relatively short period of time. Discussions on priorities for the elaboration of the results are taking place. Large-scale application of the method, working with multiple analyzers in multiple organizations demand further development particularly the development of tool support for modelers as well as the generation of IT-components. Both activities have been planned and first results are expected within the current year. In the coming weeks the IND will set priorities for elaborating details in preconditions. Furthermore, comparable interpretations of the Dutch Nationality Act, GALA and the General Data Protection Regulation (GDPR) will be made.
The Dutch Science organization NWO for sponsoring projects like the AGILE project, DL4LD, VWData and others that allow us to work on normative systems, which we believe are pivotal for creating the responsible AI systems of the future.