New Resolutions from the Agency for Access to Public Information on Personal Data Protection and Access to Information within the Public Administration
Joint Report from the Privacy and Personal Data Protection Department and the Administrative Law Department | New Resolutions from the Agency for Access to Public Information on Personal Data Protection and Access to Information within the Public Administration
On August 4, 2025, Resolutions 145/2025 (“Res. 145/2025”, available only in Spanish here) and No. 148/2025 (“Res. 148/2025”,available only in Spanish here) of the Agency for Access to Public Information (the “AAPI”) were published in the Official Gazette, introducing new provisions regarding personal data protection and access to public information within the National Public Administration.
Resolution 145/2025 – Personal Data Protection Strengthening Program
Through Res. 145/2025, the AAPI establishes the Personal Data Protection Strengthening Program for the National Public Administration, which will be implemented over a period of three years. Its overarching goal is to promote regulatory compliance and foster good practices in the handling of personal data by public sector entities, in line with the principle of proactive and demonstrable responsibility.
Among the specific objectives of the Program are:
– Guiding public agencies in the implementation of effective data protection mechanisms;
– Consolidating a network of data protection officers with administrative and technical capacities;
– Promoting the publication of privacy policies and the registration of databases in the National Registry;
– Encouraging the adoption of best practices by public officials; and Strengthening public trust in the responsible use of personal information.
In line with these goals, the Program is structured around three core action areas:
1- Institutional strengthening: Including the creation of a network of delegates, database registration, and the adoption of privacy policies across agencies.
2- Technical assistance and training: Aimed at providing ongoing education on both domestic and international standards, along with the development of regulatory and operational tools.
3- Communication and transparency: Focused on enhancing relationships among citizens, the public sector, and the private sector through awareness campaigns and monitoring activities, with particular emphasis on interjurisdictional coordination via the Federal Council for Transparency.
Res. 145/2025 repeals Disposition 7/2008 issued by the former National Directorate for Personal Data Protection, which had established the “Good Practices Guide on Privacy Policies for Public Sector Databases” and a model “Confidentiality Agreement” for public agencies.
Resolution 148/2025 – Implementation of the Access to Information Request Tracking System
Res.. 148/2025 mandates the use of the Access to Information Request Tracking System (SSSAI) by public agencies and offices listed in Section 7 of Law 27.275 on Access to Public Information —excluding the Legislative Branch, Judicial Branch, Public Prosecutor’s Office, Public Defender’s Office, and the Judicial Council.
The system is designed to:
– Record, manage, and monitor public information requests;
– Integrate with the Electronic Document Management System (GDE) to enable automatic data entry;
– Generate key performance indicators and regular statistics on the handling of requests;
– Contribute to the development of an index of frequently requested public information; and
– Serve as a repository and reporting tool to the AAIP.
Use of the system will become mandatory as of September 2025. From January 1, 2026, failure to use it will be considered a breach of the access to information regime, under the terms set forth in AAPI Resolution 80/2024, and may generate administrative responsibilities for the obligated entities
To facilitate implementation, the AAPI has also approved a User Manual within the framework of Res. 148/2025, and launched a training plan and support materials, available at campus.aaip.gob.ar.
We remain at your disposal for any additional information you may need.