In October 2025, the National Centre for Personal Data Protection of the Republic of Belarus published updated recommendations which substantially clarify enforcement practice in the area of personal data processing.
In particular, the approaches to determining the status of controllers and processors were further detailed, as well as the development of contractual and organisational models for information processing.
For the purpose of systematising the current statutory requirements and the regulator’s clarifications, an analytical overview has been prepared, intended for practical application in organisations’ business operations.
The overview contains:
The material is based on the applicable regulatory framework and the official position of the supervisory authorities.
The overview is intended for companies processing personal data in the course of entrepreneurial activity, including where contractors, outsourcing services and foreign counterparties are involved.
The material is of particular relevance for:
The overview provides recommendations on minimising regulatory risks and properly structuring personal data processing arrangements.
The latest clarifications issued by the National Centre for Personal Data Protection are aimed at strengthening oversight of the allocation of roles among participants in data processing and increasing requirements for contractual formalisation of the relevant relationships.
In the context of actively developing enforcement practice, timely adjustment of internal procedures becomes a necessary element of business legal resilience.
The full text of the analytical overview is available for review and use in practical activities.
Authors: Liudmila Yepikhava, Veranika Hrazheuskaya.
