On January 19, 2024, the National Authority for the Protection of Personal Data (ANPD) announced that after inspecting 336 entities in 2023, 132 sanctioning procedures were completed, and 2,670 personal data banks were registered. The ANPD stated that the fines for 2023 totaled more than PEN 7,600,000 (approx. $2,030,318) so far. To date, the ANPD has collected PEN 2,756,695 (approx. $736,395) due to the fined entities taking advantage of the 40% reduction for prompt payment. Some entities still have time to pay, and other fines are still being questioned through administrative litigation. Further, regarding personal data banks, the ANPD stated that procedures for 2023 were related to the registration, modification, cancellation, and registration of imposed sanctions. 

The ANPD highlighted relevant advisory opinions from 2023, including:  

• advisory opinion 1, which specified that the consent of relatives is not needed for the processing of personal data for missing persons or to disseminate personal data in the media;  

• advisory opinion 20, which specified that the personal data of health professionals can be published without consent so that the public can know their care shifts;  

• advisory opinion 22, which analyzed the quality of personal data of the socioeconomic condition of the beneficiaries of social programs that appear in the General Household Register; and  

• advisory opinion 34, which addressed the legitimate purposes for data processing and the exchange of nominal information of students between the ages of three and 17 years old. 

Lastly, the ANPD highlighted that the final version of Law No. 29733, Personal Data Protection Law will enter its final approval stage in the first months of 2024.  

You can read the press release, only available in Spanish, here.