Disclosure to third parties

Confidentiality, disclosure to third parties, publication in public sources.

Questions

Click a question to see a short answer. The detailed analysis with legal references is in the note below.

  1. Is separate consent needed to pass data to third parties?

    As a rule, yes — passing data to third parties requires consent, and the consent itself must say whether data may be passed to third parties. Without consent — only in cases expressly provided for by law.

    More in the note «Disclosure of personal data to third parties and publication»

  2. How should a relationship with a contractor processing data on the company's behalf be set up?

    The law has no separate "processor acting on instructions", so it is safer to treat passing data to a contractor as a transfer to a third party — mention it in the consent and set out the contractor's duties in the contract: confidentiality, protection measures, storage in Kazakhstan, deletion of data when the work ends.

    More in the note «Disclosure of personal data to third parties and publication»

  3. What rules apply to publishing data openly?

    Data may be published openly only with the person's consent, unless the law requires publication; where publication is mandatory, data not subject to disclosure are masked. Anyone reusing published data must cite the source. Mass extraction of data from open sources to build databases ("non-purposive extraction") is prohibited.

    More in the note «Disclosure of personal data to third parties and publication»

Key provisions

Notes

Materials

Statute

Secondary legislation

Secondary legislation395/НҚKazakhstan

Rules on the collection and processing of personal data (Order No. 395/NK of 21 October 2020) (opens in a new tab)

Detailed rules on collection and processing: consent for public dissemination, disclosure and cross-border transfer (para 4-5), a three-working-day deadline to answer data subjects (para 16), irreversible de-identification (paras 20–21), blocking and deletion (para 25).

Key provisions
paras 4 (opens in a new tab)–4-5 (opens in a new tab), para 6-3 (opens in a new tab), para 11 (opens in a new tab), para 16 (opens in a new tab), paras 17 (opens in a new tab)–18 (opens in a new tab), paras 20 (opens in a new tab)–21 (opens in a new tab), para 25 (opens in a new tab)

● Checked 26 October 2026in forceConsentCross-border transfersData subject rightsDeletion and anonymisationDisclosure to third partiesPurpose, scope and retention