Personal Data Protection Lawyers in Tbilisi, Georgia

Mapping personal data and assigning responsibility

A data protection review starts with actual processing. An employer may collect recruitment records, use access logs and store payroll information with a service provider. A platform may collect identity documents, take payments and use analytics or marketing tools across several countries. Each purpose needs a legal basis and an assessment of who makes the decisions about processing. Sensitive data, extensive monitoring and the use of biometric information require particular attention.

We map processing with the teams that operate the systems, then draft the documents they need to implement the decisions. These can include privacy notices, retention schedules, internal rules, processor agreements and procedures for access, correction or deletion requests. The aim is for the organisation to be able to explain and demonstrate how the rules work in practice.

Data protection officers and impact assessments

Georgian law requires certain organisations to appoint or designate a data protection officer. The obligation applies to specified institutions and can also turn on the scale and nature of the processing or systematic monitoring. A data protection impact assessment is a separate exercise for processing that is likely to pose a high risk. It should be considered while a product, monitoring system or data-intensive workflow is still being designed.

We assess both obligations and advise on reporting lines, responsibilities and the decisions the organisation should record. For an employee-monitoring system, the review can cover why the monitoring is needed, whose data is collected, access controls and retention. Our employment lawyers advise where workforce policies and employment documents also need attention.

International transfers and contracts with suppliers

A Georgian business can transfer data abroad through ordinary operations, including cloud hosting, access by a foreign support team or sharing records within a group. We identify where information is stored and accessed, who receives it, which onward recipients are involved and which legal basis or safeguards support the transfer. The vendor agreement should reflect the actual service, including subcontractors, security measures, assistance with requests, incident escalation and what happens to data at contract end.

Companies operating in both Georgia and Europe may need to assess the EU General Data Protection Regulation as a separate framework. Our article on GDPR and data protection covers that cross-border context. When the information is being disclosed for an acquisition, we work with our M&A lawyers on access controls and lawful disclosure in the data room.

Data breaches and State Audit Office proceedings

When a data incident is identified, the first legal questions are what happened, whose data is affected and when the organisation learned enough to identify the incident. Georgian law requires controllers to document incidents and, where the notification duty applies, notify the State Audit Office within 72 hours of identification. The assessment turns on the risk of significant harm or a significant threat to fundamental rights and freedoms. The obligation to inform affected people requires a separate assessment.

We advise on documenting the incident, assessing risk and preparing notices or responses to the supervisory authority. IT records, supplier communications and the timing of decisions are often central to that work. For a complaint or inspection, we review the request, deadline, evidence and corrective steps, including when a response should explain changes the organisation has already made.

Discuss your data protection matter in Tbilisi

Tell us what data is involved, who can access it, where it is stored and why you are seeking advice. If an incident or regulatory request is involved, include the time of discovery or receipt and any deadline. Our lawyers can review a specific processing activity, prepare an incident response or advise on a company-wide Georgian data protection programme.