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  4. GDPR/Privacy Compliance
  5. Data Protection Impact Assessments

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GDPR/Privacy Compliance

Data Protection Impact Assessments

When is a data protection impact assessment mandatory?

Under Article 31 of the Law on Personal Data Protection, the assessment is mandatory where, taking into account new technologies, the category, volume, purposes and means of processing, a risk of violation of fundamental rights is highly probable. It is also mandatory for fully automated decisions with significant consequences, processing of large volumes of special-category data, and systematic large-scale monitoring in public gathering places. A large number means not less than 3 percent of the population.

What must the assessment document contain?

The document is written and contains two parts: a description of the data category, processing purposes, proportionality, process and grounds, and an assessment of possible risks with a description of organisational and technical security measures. It is kept throughout the entire processing period, and after processing ceases for at least 1 year.

What happens if the risk cannot be reduced?

Where a high risk is identified, all necessary measures must be taken to reduce it substantially and, where necessary, the State Audit Office must be consulted. If substantial reduction is impossible through additional measures, the data must not be processed.

What fine applies to failure to carry out the assessment?

Under Article 80 of the law, failure to perform the duty entails a warning or a fine of 2 000 lari where annual turnover does not exceed 500 000 lari, and a warning or a fine of 3 000 lari above that threshold. With aggravating circumstances the fine rises to 3 000 and 5 000 lari respectively.

8 min·8 Feb 2026

What a data protection impact assessment is and which law governs it in Georgia

A data protection impact assessment is a prior, documented analysis through which the controller identifies, before launching a processing operation, what risks the planned processing creates for the fundamental rights and freedoms of individuals and what organisational and technical measures are needed to avoid or substantially reduce those risks. In Georgia this instrument exists not as a voluntary standard or a contractual practice but as a direct statutory duty: Article 31 of the Georgian Law on Personal Data Protection defines when, how and in which form the assessment must be carried out. That article is the anchor of your organisation's compliance position and of its administrative liability exposure.

In international practice this instrument is widely known by an abbreviation that spread from the European Union's general data protection regulation. It is important to keep the distinction clear: the operative norm in Georgian law is the Georgian Law on Personal Data Protection, which follows the European approach, while the EU regulation serves only as the comparative framework the Georgian law aligns with. Article 31 of the same law directly names the State Audit Office as the public body to be consulted where necessary, and the criteria for establishing the circumstances that trigger the assessment duty are set by a normative act of the General Auditor.

Updated: 18 Oct 2026