Data Protection Compliance in Georgia: What Businesses Need to Do in Practice

10.02.2026

Why Data Protection Compliance Matters for Businesses in Georgia

Georgia’s Personal Data Protection Law applies to all organizations that process personal data, regardless of size. Compliance is not limited to formal policies - it requires clear internal process-es, documented decisions, and ongoing oversight.

This checklist explains, in practical terms, how businesses can meet their obligations.

1. Identify and Document All Personal Data Processing Activities

Businesses should begin by identifying all personal data they process. This includes customer and employee data, supplier and contractor information, CCTV footage, call recordings, marketing databases, and any biometric or health data.

For each processing activity, document:

• the purpose of processing,
• the categories of personal data,
• the legal basis,
• storage location,
• access rights,
• retention period, and
• any third-party recipients.

This overview (often called a data inventory or register of processing activities) is essential for accountability and compliance.

2. Ensure a Valid Legal Basis for Each Processing Activity

Personal data may be processed only if a lawful basis applies. These include consent, performance of a contract, compliance with a legal obligation, protection of vital interests, public interest, or legitimate interest.

Each processing activity must rely on one clearly defined legal basis, and the justification should be documented. 

3. Meet Transparency and Information Obligations

Individuals must be informed about how their data is used. Businesses must provide clear and ac-cessible information explaining:

• what data is collected,
• for what purpose,
• on what legal basis, 
• how long it is retained,
• who receives it, and
• how individuals can exercise their rights.

This information is usually provided through a privacy notice on a website, in contracts, or at the point of data collection. It must be written in plain, understandable language.

4. Obtain and Manage Consent in Compliance with Legal Requirements

When processing is based on consent, it  must be freely given, specific, informed, and explicit. Pre-ticked boxes or silence do not constitute valid consent.

Businesses must keep records showing when and how consent was obtained.
Individuals must be able to withdraw consent easily at any time, and processing based on consent must stop once consent is withdrawn.

Special rules apply to children: a child may give valid consent only from the age of 16. For chil-dren under 16, consent must be obtained from a parent or legal guardian.

5. Apply Enhanced Safeguards to Special Categories of Personal Data

Special categories of personal data - such as health data, biometric and genetic data, information about criminal records, religious beliefs, or ethnic origin - require stricter protection.

In most cases, processing such data requires explicit written consent or a specific legal obligation. 

6. Limit CCTV and Monitoring to Justified and Proportionate Use

Video and audio monitoring may be used only where it is necessary and proportionate, such as for security purposes. Businesses must clearly define the purpose of monitoring, limit retention peri-ods, and restrict access to recordings.
Individuals must be informed through visible signage, and employees must receive prior written notice. 

7. Be Operationally Prepared to Handle Data Subject Requests

Individuals have the right to:

• access their personal data,
• request correction,
• request deletion, blocking, or restriction of processing, and
• withdraw consent.

Requests must, as a general rule, be answered within 10 working days. If a request is refused, the individual must be informed of the legal grounds for refusal and their right to appeal. Businesses should have internal procedures to ensure requests are identified and handled promptly.

8. Ensure Compliance with Direct Marketing Requirements

Direct marketing usually requires prior consent. Individuals must be able to opt out easily and free of charge. Once an opt-out request is received, marketing communications must stop within seven working days.

Opt-out preferences must also be respected by any third-party marketing partners.

9. Prepare for and Manage Personal Data Breaches

Businesses must have an internal procedure for detecting, containing, assessing, and documenting personal data breaches. All personal data breaches must be recorded, regardless of whether notifi-cation is required.

A personal data breach must be notified to the Personal Data Protection Service no later than 72 hours after the controller becomes aware of it. 

10. Appoint a Data Protection Officer Where Required

A Data Protection Officer (DPO) must be appointed if at least one of the following conditions is met:

• the organization is a public institution;
• the organization’s core activities involve regular and systematic monitoring of individ-uals on a large scale (for example, extensive CCTV systems or tracking technologies);
• the organization’s core activities involve large-scale processing of special categories of personal data, such as health or biometric data.

If these conditions do not apply, appointing a DPO is not mandatory. However, businesses should still designate a responsible contact person for data protection matters.

11. Regulate Relationships with Processors and Data Transfers

When personal data is processed by third parties, a written data processing agreement must be in place.

Cross-border transfers of personal data are allowed only if the legal requirements and safeguards under Georgian law are met.

12. Define Data Retention Periods and Ensure Secure Deletion

Personal data must not be retained longer than necessary for its purpose, unless retention is re-quired by another law. 

13. Implement Appropriate Technical and Organizational Security Measures

Technical and organizational security measures must reflect the risks involved. These may include access controls, authentication mechanisms, encryption where appropriate, regular backups, sys-tem updates, and staff awareness measures. Security should be reviewed periodically.

14. Document Compliance and Provide Staff Training

Companies are required to be able to demonstrate compliance at any time. This includes maintain-ing records of processing activities, consent logs, breach records, DPIAs where required, and staff training documentation.

Data protection compliance in Georgia is an ongoing process, not a one-time task. Businesses that structure compliance properly reduce regulatory risk, improve operational discipline, and build trust with customers, employees, and partners.

 

Author: Melano Svanidze, Oksana Iashagyan.