Core Legal Practice

Personal Data Protection

We help companies and organizations assess and meet the requirements of personal data protection legislation. The service covers legal analysis of data processing activities, preparation of the required documentation, risk assessment and the establishment of internal data protection procedures.

Our aim is for the organization to have a clear legal basis for processing data, appropriate internal rules and practical procedures that match its activities and the applicable legal requirements.

Who we help

  • Small and medium-sized businesses that want to put their personal data protection processes in order
  • Companies and organizations that process the personal data of customers or employees
  • Online platforms and e-commerce businesses
  • Companies that use customer databases, CRM systems or digital products
  • Employers that process the data of employees and job applicants
  • Organizations that need Data Protection Officer (DPO) services
  • Companies that transfer data abroad or use other organizations' services to process data
  • Organizations that need legal advice on data protection or support in dealings with the supervisory authority

What we handle

  • Legal assessment of personal data processing activities
  • Data protection compliance audits and identification of existing gaps
  • Data Protection Officer (DPO) services, taking into account the conditions set by law and the organization's needs
  • Drafting personal data protection policies and internal regulations
  • Organizing information and records on data processing
  • Preparing privacy notices and documents that inform data subjects
  • Preparing consent forms and other data processing documentation
  • Legal issues related to processing employees' personal data
  • Legal regulation of the relationship between the data controller and the data processor
  • Data protection impact assessments (DPIA), where required by law or by the risks of a specific processing activity
  • Legal issues related to international transfers of personal data
  • Developing internal procedures for responding to data security incidents
  • Assessing data subject rights requests and preparing responses
  • Legal advice and representation on personal data protection matters, within the scope of the relevant authorization

Key legal checkpoints

As part of the service, we review the relevant legal requirements, including:

  • Law of Georgia "On Personal Data Protection"
  • General Administrative Code of Georgia, where relevant
  • Applicable subordinate regulations on personal data processing
  • Requirements governing international data transfers and appropriate data protection safeguards
  • International standards and European approaches to personal data protection, depending on the issue

What a Data Protection Compliance Assessment Covers

Depending on the organization's activities, the service may include:

  • Assessing the purposes and legal bases of data processing
  • Identifying the categories of data processed and the data subjects
  • Reviewing how data is collected, used, stored and deleted
  • Assessing relationships with data recipients and service providers
  • Reviewing how data subjects are informed and the procedures for exercising their rights
  • Assessing data retention periods and access rules
  • Reviewing existing policies, contracts and internal documentation
  • Preparing recommendations to remedy the legal gaps identified

As a result of the assessment, the organization receives information on the issues identified and possible ways to address them. Where needed, legal support is also available while the recommendations are implemented.

Data Protection Officer (DPO) Services

In cases provided for by law, an organization may be required to appoint a Data Protection Officer. In other cases, the need for an officer or related advisory services may be determined by the organization's activities and the scale of its data processing.

The scope and format of the service are determined according to the organization's needs and the requirements of the law.

Data Protection Officer services may include:

  • Advice on personal data protection matters
  • Participation in monitoring the compliance of data processing activities
  • Supporting personal data protection awareness and informing staff
  • Advice and recommendations on data protection impact assessments
  • Supporting processes related to data subject requests
  • Assessing procedures for responding to data security incidents
  • Providing management with recommendations on data protection matters
  • Supporting dealings with the supervisory authority, within the limits set by law

Documents We Help You Prepare

Depending on the organization's activities and data processing, you may need:

  • A personal data protection policy
  • A privacy notice for websites and digital products
  • Documentation on processing the data of employees and job applicants
  • Information and related forms on processing customer data
  • Consent forms, where consent is the appropriate legal basis for processing
  • A contract, or relevant contractual clauses, between the data controller and the data processor
  • Data retention and deletion procedures
  • An internal procedure for receiving and handling data subject requests
  • A data security incident response procedure
  • Records of data processing and other relevant internal documentation

The final list of documents is determined after assessing the organization's activities, the purposes of data processing and the requirements set by law.

International Data Transfers

If your organization transfers personal data to a partner, service provider or other recipient located abroad, it is important to assess the legal basis for the transfer and the appropriate safeguards.

The service may include:

  • Assessing the international data transfer process and the parties involved
  • Determining the legal basis for the transfer and the applicable requirements
  • Reviewing contracts and documentation related to data transfers
  • Assessing legal and compliance issues relating to the data recipient
  • Determining whether additional procedures required by law are needed, and preparing the relevant documentation

Data Security Incidents

In the event of an incident involving personal data, it is important to respond promptly, assess the risks and determine the obligations set by law.

Legal support may include:

  • Assessing existing incident response procedures
  • Assessing the legal significance of the incident and its possible risks
  • Supporting the designation of responsible persons and response stages
  • Assessing obligations to inform data subjects and the relevant authority
  • Preparing the necessary documentation and notifications
  • Developing legal and organizational recommendations to prevent repeat incidents

For a specific incident, the scope of the response is determined by the factual circumstances and the applicable legislation.

Common mistakes

  • Processing personal data without a clearly defined purpose and an appropriate legal basis
  • Using a data protection policy that does not reflect the organization's actual activities
  • Treating consent as a universal legal basis for every type of data processing
  • Failing to properly inform customers and employees about how their data is processed
  • Leaving data retention periods and deletion rules undefined
  • Leaving data access rules and responsibilities unregulated
  • Not properly addressing data processing in relationships with service providers
  • Having no procedure for responding to data security incidents
  • Not assessing whether a Data Protection Officer needs to be appointed
  • Preparing documentation without studying the actual processes

What you can expect

  • A legal assessment tailored to your organization's activities
  • Identification of the main risks and gaps related to data processing
  • Preparation of the necessary documentation and review of existing documents
  • Practical recommendations for putting data protection processes in order
  • Legal support with data subject requests and incident response
  • Data Protection Officer services in an agreed format
  • Legal assessment of issues related to international data transfers

The exact scope, stages and cost of the service are determined according to the organization's needs and the volume of work.

Related guides

Frequently asked questions

Does every company need a Data Protection Officer (DPO)?

No. Whether a Data Protection Officer must be appointed depends on the circumstances set out in the Law of Georgia "On Personal Data Protection". The organization's activities and the nature and scale of its data processing need to be assessed to determine whether this obligation applies to it.

Does a small business also need a personal data protection policy?

A small business should also assess its personal data processing and the legal requirements that apply to it. The documentation and procedures needed depend on the nature of the business and the circumstances of the data processing. Being a small business does not by itself mean that data protection obligations do not exist.

What is the difference between a data protection audit and preparing a policy?

An audit assesses existing processes and documentation, identifies gaps and develops recommendations. Preparing a policy means creating a specific document. In practice, to draft effective documentation it is advisable to study the organization's actual processes first.

Do you help with issues related to international data transfers?

Yes. We can assess the legal basis for an international data transfer, the appropriate safeguards and the documentation required. The specific procedure depends on the circumstances of the transfer and the applicable legal requirements.

Can I get a one-off consultation?

Yes. A one-off legal consultation on a specific issue, a review of documentation or an assessment of a data processing activity is possible. Where needed, broader or ongoing legal support can also be agreed.

Discuss your data protection matter

Do you need data protection documentation, an assessment of your existing processes or Data Protection Officer services? Tell us about your organization and its needs so we can determine the appropriate scope of legal support.