In January 2026, the Personal Data Protection Center published its Licenses and Permits Guidelines under the Personal Data Protection Law and its Executive Regulations. For HR operations, the practical starting point is to map candidate, employee, payroll and client data; identify the organization’s role in each processing activity; and review suppliers, access, cloud or cross-border arrangements and direct-marketing activity where applicable.
Employer review points
- Document the purpose, data categories, systems, recipients and access owners for HR data.
- Identify whether the business acts as controller, processor or both for each material activity.
- Review whether any supplier, cloud arrangement, transfer or direct marketing activity requires a specific compliance assessment.
- Keep the official guidance, specialist advice and resulting actions in a controlled record.
General information only; licensing, legal basis and processing obligations depend on the actual activity and should be reviewed by the appropriate specialist.