April 2013
NEWSLETTER

State Service on Personal Data Protection Planning to Inspect Company Websites

On 22 March 2013 the State Service on Personal Data Protection (the "Service") issued its Decision No. 6 On Practice of Implementation the Personal Data Protection Law with Respect to Data Processing on the Web-Resources (the "Decision").

Under the Decision, while examining some Ukrainian websites the Service has detected the following defects/infringements:

  • In the process of data collection, the data subject was not informed about the database owner, scope and content of personal data retained, his/her rights, the aim of data processing, and third parties to which the data are transferred;
  • The scope of processed personal data is excessive in relation to the announced purpose of processing;
  • The data processing policies were only published on the web-site, but not defined in the relevant internal documents of the database's owner as provided by law.

In view of the above, the Service, in particular, has decided to:

  • Include verification of compliance by web-sources in the Service's regular audit plans;
  • Consider companies involved in the processing of personal data on the web-resources for inclusion in the Service's inspection plans for II and III quarters of 2013.



For further information please contact partner Oleksandr Padalka
and associate Yulia Yanyuk

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