The Law of Ukraine on Personal Data Protection (the
"Law") became effective from 1 January
2011. However, the Law was not fully enforceable due to the lack of
secondary legislation concerning clarification of the
provisions of the Law and the practical regulation of the data
protection system.
One of the mandatory requirements set out by the Law is the
registration of any personal data database with the State Register
of the Personal Data Databases (the "State
Register"). The State Register should be separately
created by the regulatory authority in data protection area, i.e.
by the State Service for Personal Data Protection (the
"SSPDP").
According to the Decree on the Approval of the Regulation on the
State Register of the Personal Data Databases (the
"Decree") adopted by the Cabinet of
Ministers of Ukraine on 25 May 2011 and effective since 21 June
2011, the State Register should be created and become functional
from 1 July 2011. The Decree also requires that
