Federal Council for Transparency – Guidelines for the Formulation of a Personal Data Protection Plan
Report from the Department of Data Privacy & Data Protection
On February 22, 2024, the Working Commission on “Data Governance and Privacy Protection,” which is part of the Federal Council for Transparency – composed of a representative from each province and a representative from the City of Buenos Aires, and chaired by the Director of the Public Information Access Agency – developed the “Personal Data Protection Plan”.
The main objective of this document is to formulate specific personal data protection plans that contribute to and facilitate the implementation of a privacy culture in each of the public agencies. To this end, the “Personal Data Protection Plan” delves into various issues such as:
(i) Current Legal Framework: It highlights the importance of Law 25.326 on Personal Data Protection and its regulations, emphasizing the need for updates to harmonize regional and international standards.
(ii) Definition and Treatment of Personal Data: It incorporates a broad definition of personal data, including sensitive data, and emphasizes responsible handling within the public sector, respecting existing regulations and ensuring security and privacy.
(iii) Personal Data as a Human Right: It reaffirms the protection of personal data as a fundamental human right, promoting informational self- determination and personal control over shared information.
(iv) Plan Development: It urges each public agency to develop a comprehensive plan that includes policies, procedures, and ethical practices for managing personal data, ensuring effective protection and regulatory compliance.
(v) Privacy Policy: It points out the importance of establishing clear and accessible privacy policies, outlining specific responsibilities in data handling, setting clear guidelines on the purpose of processing, expiration, data sharing, international data transfer, confidentiality, security measures, rights of the data subjects, among others.
(vi) Cloud Hosting: It addresses the growing relevance of cloud hosting, advocating for a careful selection of providers that meet high security and privacy standards, especially in the context of international data transfers.
(vii) Future Advances and Challenges: It highlights the need to strengthen the development of data protection plans, improve internal training, and promote public awareness of the importance of data privacy.
You can access the reference standard through the following link: Personal Data Protection Plan – Federal Council for Transparency.
Please, do not hesitate to contact us should you require any additional information on this matter.
Sincerely,
Emilio Beccar Varela
Florencia Rosati