According to Article 19, paragraph 1 of the Law on Personal Data Protection, the person who processes personal data is obliged to maintain a catalogue of the file system of personal data.

• A file system refers to a set of data in which data is sorted and accessed according to certain criteria. 

Requirements for the contents of a file system directory

The following information should be displayed in the file system directory:

• the name of the file system;
• name and address of the data processor and authorised person, place of storage or(s) processing of the data;
• the legal basis for data processing;
• Data subject category;
• the category of data in the file system;
• data processing purposes;
• data retention period;
• the fact and grounds for the restriction of the data subject’s rights;
• Recipients of data placed in the file system and their categories;
• information on the transfer of data to other states and international organisations and the legal basis for such transfers;
• a general description of the procedure established to protect data security.

Before creating a file system and entering a new category of data into it, the data processor must communicate the above information in writing or electronically to the personal data protection inspector, who in turn maintains a file system catalogue register.

The said register is publicly available at https://catalog.pdp.ge/.

The data processor is also required to notify the inspector of a change to the file system directory no later than 30 days after the change has taken place.

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