Purpose, scope and retention

The list of necessary data, use only for stated purposes, retention periods.

Questions

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

  1. How should a company draw up a list of personal data that is necessary and sufficient for its tasks?

    The list is drawn up before collection starts — for each company task (hiring, sales, delivery) it states the purpose, only the data the task cannot do without, and the document or rule the task stems from. Unnecessary data are left out and not collected. The list is approved by an internal document and revised when processes change.

    More in the note «Purpose, scope and retention of personal data»

  2. How is the retention period determined, and what happens when it expires?

    The general rule is to keep data until the purpose is achieved and then destroy or delete them. Where the law sets a mandatory period (for example, employment contracts and personnel files — 75 years, customer due diligence records in finance — at least five years), data are kept for that period and then destroyed or deleted.

    More in the note «Purpose, scope and retention of personal data»

  3. Can data be used for a new purpose?

    Data may be used only for the purposes stated at collection; a new purpose generally requires new consent. The law has no "compatible purpose" mechanism like the GDPR's.

    More in the note «Purpose, scope and retention of personal data»

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

Secondary legislation279-НҚKazakhstan

List of standard documents of state and non-state organisations with retention periods (Order No. 279-NK of 17 June 2025) (opens in a new tab)

Retention periods for standard documents of any organisation. For HR: internal personal data policies — permanently; employment contracts and personnel files — 75 years; documents of rejected applicants — until no longer needed; employees' consent forms — 1 year.

Key provisions
items 460–467

● Checked 26 October 2026in forcePurpose, scope and retentionEmployment

Secondary legislation199/НҚKazakhstan

Rules on determining the list of personal data necessary and sufficient for the owner's or operator's tasks (Order No. 199/NK of 21 June 2023) (opens in a new tab)

How to build the inventory of processed data: analyse tasks before processing, state clear and lawful purposes, exclude excessive data (paras 3–4), make the inventory accessible (para 5); a template is annexed. Purpose limitation and minimisation in practice.

Key provisions
paras 3 (opens in a new tab)–5 (opens in a new tab)

● Checked 26 October 2026in forceProcessing principlesPurpose, scope and retention