Personal Data Protection.
CIRCULAR
Data Privacy & Data Protection Department Report: “Personal Data Protection”
Dear Sir or Madam,
On October 22, 2018 Resolution N°132/2018 (the “Resolution”) of the Access to Public Information Agency was published in the Official Gazette, introducing amendments to the registration system for the registration, modification and deregistration of private and public state and non-state data bases.
As of the entry into force of the Resolution, all the procedures of the National Database Registry should be processed exclusively through the Distance Procedures Platform (“TAD”, by its Spanish acronym), entering with a level 2 or higher tax code of the Federal Administration of Public Revenues (“AFIP”, by its Spanish acronym), or the Electronic Document Management system.
In this connection, Articles 5 and 6 of the Resolution set forth that the data controller must be registered within the framework of the new technical registry procedure implemented. Those responsible for private databases will have until October 31, 2019, while those responsible for public databases will have until February 28, 2019.
Likewise, the Resolution provides that the procedure is free and does not require annual renewal.
Finally, it should be noted that, although the Resolution does not establish the obligation to renew the data bases annually, it will be mandatory to report any update or modification in the data of the data controller and regarding the data of the databases and it will be the data controller’s responsibility to comply with this duty, since the registration has the character of an affidavit.
Please, do not hesitate to contact us should you require any additional information on this matter.
Sincerely.
Emilio Beccar Varela
Florencia Rosati
Mariel Marcet
Martín Beccar Varela