Participation in the public discussion of the draft Law on Personal Data Protection

27.07.2026

The Association proposed adding the following words to paragraph 3 of Article 9(1) "Processing Personal Data Using Technical Means for Video and Audio Recording": "The operator (authorized person) has the right to audio record a telephone conversation without the consent of the personal data subject when the latter contacts emergency (dispatch) services (with the exception of emergency psychological assistance services (helplines) and in other cases stipulated by law."

It was proposed to change to the following:  "The operator (authorized person) has the right to audio record a telephone conversation without the consent of the personal data subject:

  • when the latter contacts emergency (dispatch) services (with the exception of emergency psychological assistance services (helplines);
  • when the latter contacts a legal entity that processes the personal data of more than one hundred thousand individuals;
  • in other cases stipulated by law."