Responsible person and internal policies

The person responsible for organising processing, the processing policy and other internal documents.

Questions

Click a question to see a short answer. The detailed analysis with legal references is in the note below.

  1. Who must appoint a responsible person, and what are their duties?

    All legal entities that own or operate personal data, except courts, must appoint a responsible person. This person monitors compliance within the organisation, informs staff of the requirements and oversees how people's requests are handled. Their contact details are given in a breach notification.

    More in the note «Responsible person and internal policies»

  2. What internal documents must an operator have?

    Everyone needs an approved list of personal data and policy documents on processing and protection. Beyond that, by category — small operators need a list of people with access and internal procedures, medium ones also an inventory of systems, an incident response procedure, staff training and internal control, and large ones also a security assessment and an independent audit.

    More in the note «Responsible person and internal policies»

  3. How does the responsible person differ from a GDPR DPO?

    A European DPO is mandatory only in certain cases and must be independent and have expert knowledge. In Kazakhstan a responsible person is mandatory for all legal entities, but the law sets no requirements on qualifications or independence — the role can be combined with other work.

    More in the note «Responsible person and internal policies»

Key provisions

Notes

Materials

Statute

Secondary legislation

Secondary legislation179/НҚKazakhstan

Rules on personal data protection measures for owners, operators and third parties (Order No. 179/NK of 12 June 2023) (opens in a new tab)

The main secondary act on protection measures, restated in September 2026: notification, operator size categories and tiered measures, restricted-access data (incl. cryptography), local collection and storage in a server room or data centre in Kazakhstan, the responsible person, and breach notification within one working day.

Key provisions
paras 3 (opens in a new tab)–7 (opens in a new tab), paras 8 (opens in a new tab)–14 (opens in a new tab), para 15 (opens in a new tab), para 16 (opens in a new tab), para 18 (opens in a new tab), paras 19 (opens in a new tab)–20 (opens in a new tab), para 23 (opens in a new tab)
In force from
21 September 2026

● Checked 26 October 2026in forceBreaches and notificationsTypes of personal dataData localisationNotification and register of operatorsResponsible person and internal policiesSecurity measures