Helsinki Citizens' Assembly-Vanadzor

The RA Personal Data Protection Agency confirmed the issue raised by HCAV regarding publication of children’s personal data

August 15, 2023

Right to Respect for Private and Family Life | Activities | Media Monitoring | Law Enforcement Practice Analysis | Rights | State Institutions | Activities of Local Self-Government Bodies | Civilian Oversight and Monitoring | Legislative Proposals | Legislative Proposals and Analysis

Individuals’ sensitive personal data should not be published based on the decisions of community heads and the Council of Elders, and the proportionality of publishing such data is prima facie not justified.


In early 2023, HCAV addressed the issue of including and publishing children’s personal data and private life information in the local government’s decisions, in particular, in the local government’s decisions concerning the issue of minors’ reunification with their families, the conditions serving as grounds thereof, issues related to their care and upbringing.  Publication of this information falls within the scope of a minor’s right to respect for private life, it interferes with the said right and contradicts the best interest of the child.


In order to eliminate such violations, the Organization recommended legislative and practical solutions.As an effective legislative guarantee for the protection of children’s personal data, it was recommended to envisage, in Article 11 of the Law on Local Self-Governance, regulations regarding depersonalized publication of the community residents’ personal data, as well as the prohibition on publishing data related to private life. As a practical solution, it is recommended to depersonalize information related to a minor’s private life in official websites of the local government where decisions are published. 


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