Types of personal data

Publicly available and restricted-access data; biometrics; data requiring special treatment.

Questions

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

  1. What counts as restricted-access data, and what follows from that?

    These are data to which access is restricted by law — for example, medical information (medical confidentiality), fingerprint and genomic information, and information covered by banking secrecy. Stricter rules apply — confidentiality, extra protection measures (encryption, access logs), processing only through systems in Kazakhstan — and the operator moves up a category.

    More in the note «Types of personal data»

  2. How does the law define publicly available data and identifiers after 2026?

    Publicly available data are data not subject to confidentiality and freely accessible with the person's consent; as a rule, data may be published only with consent. Identifiers are what makes a person identifiable — full name taken together, the IIN, an image of the face and a facial biometric vector. Information becomes personal data when it is linked to such an identifier.

    More in the note «Types of personal data»

  3. Where are the rules classifying information as restricted-access (medical, genetic, banking)?

    There is no single list — it has to be assembled from sector laws: the Health Code (medical confidentiality), the Law on Fingerprint and Genomic Registration, the Banking Law (banking secrecy) and the Law on Access to Information. Links to these acts are collected in the library.

    More in the note «Types of personal data»

  4. Does Kazakhstan law have an equivalent of the "special categories" in Article 9 GDPR?

    There is no direct equivalent. In the EU, special categories are defined by content (health, religion, political opinions and so on); in Kazakhstan, by whether some law restricts access to the information. So political opinions or religion, for example, are not restricted-access data as such.

    More in the note «Types of personal data»

Key provisions

Notes

Materials

Code

Code360-VIKazakhstan

Code of the Republic of Kazakhstan "On Public Health and the Healthcare System" (opens in a new tab)

Personal medical data, the fact of seeking care, health status and diagnosis constitute medical secrecy (Art. 273(1)); Art. 273 lists when they may be disclosed without consent, and Art. 62 covers digital resources with medical data.

Key provisions
Art. 62 (opens in a new tab), Art. 273 (opens in a new tab)

● Checked 26 October 2026in forceTypes of personal dataHealthcare

Statute

Statute94-VKazakhstan

Law of the Republic of Kazakhstan "On Personal Data and Their Protection" (opens in a new tab)

The core statute: definitions, scope, the in-country storage rule (Art. 12) and cross-border transfers (Art. 16). Notification of processing (Art. 10-1) and operator size categories (Art. 25-1) apply from 25 August 2026.

Key provisions
Art. 1 (opens in a new tab), Art. 3 (opens in a new tab), Art. 10-1 (opens in a new tab), Art. 12 (opens in a new tab), Art. 16 (opens in a new tab), Art. 25-1 (opens in a new tab), Art. 29 (opens in a new tab)

● Checked 26 October 2026in forceAutomated processing and AIBreaches and notificationsConsentCross-border transfersTypes of personal dataData subject rightsDeletion and anonymisationDisclosure to third partiesLiabilityData localisationNotification and register of operatorsProcessing principlesProcessing without consentPurpose, scope and retentionRegulator and state supervisionResponsible person and internal policiesScope and key termsTelecommunicationsSecurity measures

Statute40-VIKazakhstan

Law of the Republic of Kazakhstan "On Dactyloscopic and Genomic Registration" (opens in a new tab)

A rare example of an express statutory rule: fingerprint and genomic information is restricted-access personal data (Art. 8(1)).

Key provisions
Art. 8 (opens in a new tab)

● Checked 26 October 2026in forceTypes of personal data

Statute401-VKazakhstan

Law of the Republic of Kazakhstan "On Access to Information" (opens in a new tab)

Defines "restricted-access information": state secrets, personal, family, banking and commercial secrets, medical secrecy and other legally protected secrets, restricted-access personal data and restricted official information (Art. 1(8)).

Key provisions
Art. 1 (opens in a new tab)

● Checked 26 October 2026in forceTypes of personal data

Secondary legislation

Secondary legislation179/НҚKazakhstan

Rules on personal data protection measures for owners, operators and third parties (Order No. 179/NK of 12 June 2023) (opens in a new tab)

The main secondary act on protection measures, restated in September 2026: notification, operator size categories and tiered measures, restricted-access data (incl. cryptography), local collection and storage in a server room or data centre in Kazakhstan, the responsible person, and breach notification within one working day.

Key provisions
paras 3 (opens in a new tab)–7 (opens in a new tab), paras 8 (opens in a new tab)–14 (opens in a new tab), para 15 (opens in a new tab), para 16 (opens in a new tab), para 18 (opens in a new tab), paras 19 (opens in a new tab)–20 (opens in a new tab), para 23 (opens in a new tab)
In force from
21 September 2026

● Checked 26 October 2026in forceBreaches and notificationsTypes of personal dataData localisationNotification and register of operatorsResponsible person and internal policiesSecurity measures