Ukraine Personal Data Law compliance and requirements, so your data handling holds up when someone asks.

What it is

What is Ukraine's Law on Personal Data Protection and what is it used for?

The Law on Personal Data Protection is Ukraine's personal data protection law. It applies to processing done wholly or partly by automated means and to personal data held in, or meant for, a filing system. Bases for processing include consent, a legal permission, a contract, vital interests, a legal duty and the controller's legitimate interests where these are not overridden by the person's rights.

The Ukrainian Parliament Commissioner for Human Rights and the courts control compliance with the Law (Article 22). The practical test: for any personal data you hold, could you show its purpose and basis, who was told, how it is protected and where it goes?

Current law. Law No. 2297-VI of 1 June 2010, printed on zakon.rada.gov.ua as current, in the edition of 14 June 2025 (amending law No. 4240-IX); Article 30 provides that it takes effect on 1 January 2011. Confirm current wording and the authority's guidance with your legal advisers.

Who it is for

Who needs to comply with Ukraine's Law on Personal Data Protection?

The Law reaches organisations of every size that handle personal data in Ukraine. Organisations usually come to Sterling for a structured programme from one of four directions:

• Any business processing personal data of customers, staff or users in Ukraine. The Law applies to automated processing and to data in or meant for a filing system, and each processing needs one of the bases it lists.
• Outsourcers and software firms acting as processors. A processor works under a written contract and may process only for the purpose and scope that contract sets.
• Organisations whose processing poses a special risk. They must notify the Commissioner within the period the Law sets, in the form the Commissioner defines, and report changes.
• Employers, clinics and insurers handling special categories. Health, biometric, genetic and similar data are prohibited from processing unless an exception such as unambiguous consent or employment law applies.

The aim is handling of personal information that you control and can evidence. Compliance depends on how the rules are applied every day, not on a policy document alone.

Requirements

What are the main Ukraine Personal Data Law requirements?

Strip away the vocabulary and Ukraine's personal data law requires a business to comply in six areas of personal data handling. The list below puts each one in business terms; the Law and the regulator's guidance give the full wording and exceptions.

• Every processing has a lawful basis: personal data is processed for a stated, legitimate purpose on a recognised basis such as consent, a contract, a legal duty or legitimate interests, and no more than needed.
• People are told and can use their rights: individuals learn who collects their data, what and why when it is collected, and can see it, object, correct, delete, withdraw consent and complain to the Commissioner or a court.
• Sensitive data is handled only under exceptions: health, biometric, genetic, political, religious and similar data is prohibited from processing unless a narrow exception applies, such as unambiguous consent or employment law needs.
• Data is protected and processors are bound: controllers, processors and third parties protect data against loss, destruction and unlawful processing, and processors work only within a written contract's purpose and scope.
• Special-risk processing is notified: processing that poses a special risk to people's rights is notified to the Commissioner in the form set, changes are reported, and a responsible unit or person organises protection.
• Transfers abroad rely on protection or an exception: data goes to foreign recipients only where the receiving state ensures adequate protection, or on listed grounds such as unambiguous consent, a contract, vital interests or safeguards from the controller.

Compliance route

How do you achieve Ukraine Personal Data Law compliance?

There is no certificate at the end of this route. Compliance is something your organisation demonstrates, to the Commissioner for Human Rights if a complaint or incident arises, and to customers who ask. Sterling helps you build and run the programme; interpretation of the law in contested cases remains with your legal advisers and, ultimately, the regulator and the courts.

1. 01
   Map the personal information you handle.Customers, staff, users and suppliers: what is collected, for which purpose, on which basis, where it is stored, who processes it for you and whether it leaves Ukraine.
2. 02
   Gap analysis: compare current practice with the Law.Each area of the Law reviewed against what actually happens, with actions, owners and dates agreed.
3. 03
   Put the controls and routines in place.Complete the formalities the Law asks for, rewrite notices and consent wording, put security measures and processor contracts in place, name who is responsible and agree a breach procedure.
4. 04
   Test the programme and review the results.Internal review of samples, a simulated incident or data-subject request, and a management review that closes findings with evidence.
5. 05
   Operate, demonstrate and keep it current.Answer requests, record incidents and report them as the Law requires, keep formalities current, review transfers, refresh training and follow the Commissioner for Human Rights's guidance as it is issued.

Check the route before you sign. The Law creates no certificate of compliance, so treat any offer of a "Ukraine Personal Data Law certificate" with suspicion. If a customer wants independent assurance, ISO/IEC 27701 or ISO/IEC 27001 is certifiable by an accredited certification body; confirm the body's accreditation scope directly with the accreditation body concerned.

Cost

How much does Ukraine Personal Data Law compliance cost?

The cost of a Ukraine Personal Data Law programme is driven by how much personal information you hold, how many systems and suppliers touch it, and how much already works. Your proposal shows each component, with what is included and what remains for your legal advisers.

Timeline

How long does Ukraine Personal Data Law compliance take?

Timing depends on how scattered your personal information is, how quickly system owners respond and how much has to change. Your proposal sets out the phases for your scope, long enough to map the information, fix the gaps and show that requests and incidents are handled the way the procedures say.

If a customer or contract has set a date, tell us at the outset and we will say plainly what can be in place by then and what should follow.

Your engagement

What your Ukraine Personal Data Law engagement includes

Your scope covers the full programme, from the information map to evidence that runs. Sterling does not certify, attest or validate compliance with the Law, and the Law creates no certificate of compliance; the Commissioner for Human Rights supervises it, and we work alongside your legal advisers.

• Information map, gap analysis and plan

  Sources, systems, suppliers and overseas flows, with actions and owners agreed.

• Policies, notices and procedures

  Notices, consent wording, request, security and breach procedures, processor contract terms and transfer documents, drafted from Sterling's own templates with your teams.

• Effivity ISO & GRC software

  Registers, requests and incidents managed in Effivity, included with the engagement at no additional cost.

• Training for everyone

  Internal auditor training for your review team, as applicable to your standard, and preferential Sterling Academy access, including complimentary awareness training for your people as part of the engagement.

• Internal review and management review

  Sample testing, an incident exercise and findings closed with evidence.

• Formalities support

  Help preparing the formalities the Law asks for and the responsible person's role, with findings closed with evidence.

Sterling OS™ sets how we deliver. Design™ is guided support, where your team builds the programme with our consultants' direction; Drive™ is managed support, where our consultants do most of the work with your input. You choose one of the two, not both in sequence. Once the programme is operating, Sustain™ keeps reviews, training and updates on schedule, and Automate™ is Effivity, where the records live.

The Ukrainian Parliament Commissioner for Human Rights and the courts control compliance with the Law (Article 22).

Often combined with

Standards organisations pair with Law on Personal Data Protection (Ukraine)

• ADGM Data Protection Regulations 2021ADGM data protection compliance for entities under the 2021 Regulations: lawful bases, DPO, impact assessments, 72-hour breach notice and transfers, all-inclusive proposal.
• APEC CBPRAPEC CBPR certification and requirements explained: Global CBPR and PRP, Accountability Agent review, annual renewal and how Sterling prepares your team.
• APPI (Japan)APPI compliance for Japan's Act on the Protection of Personal Information: the requirements, PPC breach reporting, cross-border rules and an all-inclusive programme.
• Bahrain PDPLBahrain PDPL compliance and requirements explained: consent, notification to the Authority, transfers abroad, 72-hour breach reporting, rights, cost and timing.
• CCPA / CPRACCPA compliance and requirements under the CPRA: notices, consumer rights, opt-outs, risk assessments, cybersecurity audits and ADMT, in an all-inclusive programme.
• Cyber and Data Protection Act (Zimbabwe)Zimbabwe's Cyber and Data Protection Act [Chapter 12:07]: POTRAZ licensing, lawful processing, security and transfers, built into a programme.