CM2104 Creating second-class Union citizenship? Unequal treatment of Union citizens with dual nationality in ECRIS-TCN and the prohibition of discrimination

In this comment, we express our concerns regarding Regulation 2019/816, establishing a new large-scale EU database, ECRIS-TCN (hereafter the Regulation). In this database, personal data (including fingerprints and facial data) of third-country nationals with a criminal conviction in a Member State will be registered. The new database will also register similar information of Union citizens who also hold the nationality of a third country.