Personal Data Protection

12 March 2025
Anna Bakradze, Lawyer, Attorney, Personal data protection officer
1. What is personal data?
Personal data is any information that can directly or indirectly identify a natural person, including:
  • First name, last name;
  • Identification number;
  • Geolocation data;
  • Photo/video recording;
  • Physical, physiological, mental, psychological, genetic, economic, cultural or social characteristics and etc.
2. What is special categories of data?
Personal data that requires a higher level of protection.

Special categories of data includes information related to a natural person’s:
  • Racial or ethnic origin;
  • Political views;
  • Religious, philosophical, or other beliefs;
  • Health;
  • Sexual life;
  • Biometric and genetic data, processed for the purpose of uniquely identifying a natural person, etc.
3. What does processing of personal data mean?
Data processing refers to any action performed on personal data, including:
  • Collection and/or obtaining;
  • Access and/or disclosure;
  • Modification and/or storage;
  • Photographing, video monitoring, and/or audio monitoring;
  • Use, deletion, and/or destruction.
4. Who/What does the "Personal Data Protection Law" of Georgia apply to?
  • The processing of data by automated means and semi-automated means within the territory of Georgia;
  • The processing of data by non-automated means that are part of a filing system or are being processed to be included in a filing system;
  • The processing of data using technical means available in Georgia by a controller not established in Georgia, except in cases where the technical means are used solely for data transit.
5. Who is the data controller?
Any natural person, legal entity, or public institution that independently or jointly with others determines the purposes and means of data processing and carries out data processing either directly or through a processor.
6. Who is the processor?
Any natural person, legal entity, or public institution that processes data for or on behalf of the controller (except employees of the data controller).
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MARIA GUSEINOVA
Leading Manager of Commercial Department