Process for Registering Databases in the Ukraine Will Change

We have learned that the Ukrainian Justice Ministry recently issued a new regulation that governs the registration of databases that contain personally identifiable information. Under the regulation, companies will no longer need to register all such databases. Instead, they need to notify the Office of Ombudsman about any uses of personal information that might pose a "special risk" to individuals' rights and freedoms. This notification, in the form of a database registration, would be submitted to the Office 30 days from when data processing starts. The change is set to start on July 1, 2014. 

TIP: Like many countries, the Ukraine has registration requirements for companies that maintain databases of personally identifiable information. Registration processes, and requirements of when an entity needs to register, change over time. Companies should take into account such local requirements when developing global privacy programs.

This tip has been created for information and planning purposes. It is not intended to be, nor should it be, substituted for legal advice, which turns on specific facts.