In accordance with the Law of Georgia on Personal Data Protection (the “Law”), the Personal Data Protection Inspector (the “Inspector”) was appointed by the Government of Georgia this summer. The Inspector's office is now fully functional (although certain functions with respect to the private sector will only enter into force on January 1st 2016) and a meeting was held with the public and private sector last Friday. The Inspector informed the audience that her office is about to start implementing and enforcing the Law. Accordingly, every public or private entity (which has at least 20 employees) has to submit information about its “personal data filing system” to the Inspector prior to January 30, 2014.

The Law defines “personal data filing system” as any structured set of personal data which is arranged and accessible according to the specific criteria.

The form of submission (i.e. notification form) has been elaborated by the Inspector's office and approved by the Inspector. Note also that transfer of personal data abroad (even to the founding entity or head office) is subject to the Inspector's prior approval.

Please let us know if you have any questions.