Description

Personal Data Protection Center released Lawful Bases of Processing Guidelines

On 26 January 2026, the Personal Data Protection Center (PDPC) released the Lawful Bases of Processing Guidelines, Version 1.1, which outline the lawful bases for processing personal data under Article 6 of the Personal Data Protection Law enacted by Law No. 151 of the year 2020 and the Executive Regulations issued by Decision No. 816 of 2025. The Guidelines clarify the lawfulness principle and describe how Data Users may identify and assess an appropriate lawful basis prior to initiating a processing activity and how compliance may be documented. The Guidelines set out six lawful bases, namely data subject’s consent, fulfilment of a contractual obligation, fulfilment of a legal obligation, legitimate interest, claim or defence of a legal right, and execution of court judgments or orders from competent investigative authorities. They describe conditions for valid consent, including additional written consent conditions for sensitive personal data and guardian consent requirements for children, and explain how necessity and data minimisation considerations apply across the relevant lawful bases.

Original source

Scope

Policy Area
Data governance
Policy Instrument
Data protection regulation
Regulated Economic Activity
cross-cutting
Implementation Level
national
Government Branch
executive
Government Body
data protection authority

Complete timeline of this policy change

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2026-01-26
adopted

On 26 January 2026, the Personal Data Protection Center (PDPC) released the Lawful Bases of Process…