Security measures

Legal, organisational and technical safeguards; requirements for restricted-access data.

Questions

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

  1. Which protection measures are mandatory for all operators, and which for restricted-access data?

    All operators protect data against unauthorised access, detect breaches in time and limit their consequences, and the specific set of measures depends on the operator's category. Restricted-access data have their own mandatory set — defined processing purposes, a blocking procedure, event and user activity logs, integrity control, encryption in storage and transfer, authentication, and processing through systems in Kazakhstan.

    More in the note «Personal data security measures»

  2. What are the requirements for cryptographic protection and logging?

    Restricted-access data are stored and transferred using certified cryptographic protection of at least level 3 under the Kazakhstan standard (except for cross-border transfer). For such data, database event logs and user activity logs are kept; databases of more than 100,000 records require user identification and authentication, including biometric.

    More in the note «Personal data security measures»

  3. Which measures are mandatory for small, medium and large operators?

    Small operators (up to 10,000 people) — a list of data and purposes, a list of people with access, a responsible person, internal documents, access control, logging, backups, anti-malware protection and secure channels. Medium (up to 500,000) — plus an inventory of systems, role-based access, multi-factor authentication, an incident response procedure, staff training, vulnerability analysis and internal control. Large — plus security assessment, independent audit, monitoring, control of privileged users, penetration testing and recovery after breaches.

    More in the note «Personal data security measures»

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

Statute418-VKazakhstan

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

The former Informatisation Law. Relevant here: cybersecurity centres must alert the data protection regulator within three hours of a personal data breach (Arts 7-4, 7-5 etc.), subjects are informed via eGov (Art. 7-1), and personal data resources must be protected (Art. 56).

Key provisions
Art. 7-1 (opens in a new tab), Art. 7-4 (opens in a new tab), Art. 7-5 (opens in a new tab), Art. 14 (opens in a new tab), Art. 16 (opens in a new tab), Art. 56 (opens in a new tab)

● Checked 26 October 2026in forceBreaches and notificationsSecurity measures

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

Secondary legislationKazakhstan

Inspection checklist on compliance with personal data legislation (joint order, March 2024) (opens in a new tab)

The 33-item list used in inspections; handy as a ready-made compliance checklist (consent, purposes, localisation, transfers, DPO, logs, encryption). Wording predates the 2026 amendments.

Key provisions
items 1–33

● Checked 26 October 2026in forceData localisationRegulator and state supervisionSecurity measures