Telecommunications

Subscriber service information and its cross-border transfer.

Questions

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

  1. What is subscriber service information, and how is it protected?

    These are subscriber data generated in communication networks — numbers, IMEI, IIN or BIN, billing, location, IP addresses and resources visited. Operators keep them in Kazakhstan and provide them to bodies conducting operational-search and counterintelligence activities; to others — only with the subscriber's consent and as provided by law.

    More in the note «Subscriber service information in telecommunications»

  2. What special cross-border transfer rules does the Communications Law set?

    Transferring service information outside Kazakhstan is prohibited even with the subscriber's consent — except when a Kazakhstan subscriber uses services abroad (roaming). This is stricter than the general personal data rule, under which consent allows transfer.

    More in the note «Subscriber service information in telecommunications»

Key provisions

Notes

Materials

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

Statute567-IIKazakhstan

Law of the Republic of Kazakhstan "On Communications" (opens in a new tab)

Special regime for subscriber service information (numbers, device IDs, billing, location, IP addresses, Art. 23-1): it must be stored in Kazakhstan and may not be transferred abroad except to serve Kazakhstan subscribers roaming abroad (Art. 15(1)(2)).

Key provisions
Art. 15 (opens in a new tab), Art. 23-1 (opens in a new tab)

● Checked 26 October 2026in forceCross-border transfersData localisationTelecommunications