Normative alert: Changes in the Registry of Offenders under the Personal Data Protection and “Do Not Call” Laws
Data Privacy & Data Protection – Cibersecurity Department Report | Normative alert: Changes in the Registry of Offenders under the Personal Data Protection and “Do Not Call” Laws.
Dear All,
On September 30, 2025, the Agency for Access to Public Information (“AAPI”) published Resolution 179/2025 (the “Resolution”), which introduces significant changes to the structure and information requirements of the Register of Offenders (the “Register”) under Laws No. 25,326 on Personal Data Protection and No. 26,951 on the National “Do Not Call” Registry, in order to optimize its usefulness and align it with current administrative standards (available here).
The Resolution amends paragraph (b) of Section 5 of AAPI Resolution No. 126/2024, eliminating the obligation to record in the case file the degree of compliance, the final decision rendered, and the offender’s repeat-offender status. From now on, it is only required to state the nature of the offense committed, the penalty imposed, the appeals or remedies filed, and other elements of interest to the National Directorate for the Protection of Personal Data.
This measure seeks to advance a reengineering of the Register to strengthen its function as a consultation and support tool for the case officers and authorities of the National Directorate for the Protection of Personal Data in making decisions on sanctions, taking into account the information available and the agency’s statistical needs. The Resolution is aligned with the good practices of regulatory simplification and continuous improvement established by Decree No. 891/17.
We remain at your disposal for any further information you may require.
Yours sincerely,