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| Comparative Infographic: Data Mining Bill USA, EU GDPR, Ukrainian Law |
📊 DSS BI consulting+ | Analysis of Ukraine’s Social Sphere Data Law and Its Compliance with International Standards
Executive Summary
The recently adopted Ukrainian law on the Unified Information System of the Social Sphere introduces large-scale data integration across multiple state registers. While it strengthens technical safeguards such as digital signatures, audit trails, and security oversight by the Security Service of Ukraine, it falls short of fully aligning with international data protection norms, particularly the EU GDPR and the principles outlined in the Data Mining Bill.
Key gaps include the absence of a comprehensive “right to be forgotten”, limited transparency regarding who accesses personal data, and vague accountability mechanisms. These shortcomings raise concerns about excessive data concentration and potential misuse.
🔍 Comparative Analysis: Ukrainian Law vs. GDPR & Data Mining Bill Principles
| Principle | GDPR / Data Mining Bill | Ukrainian Law | Compliance |
|---|---|---|---|
| Right of Access | Full access to personal data and information on processors | Access only to own data, no details on officials accessing it | ❌ Limited |
| Right to Rectification | Mandatory correction of inaccurate data | Provided, but mechanism unclear | ⚠ Partial |
| Right to Erasure (“Right to be Forgotten”) | Broad right to deletion | Only if data collected unlawfully | ❌ Restricted |
| Transparency | Obligation to inform subjects about processing and access | Citizens cannot see who accessed their data | ❌ Insufficient |
| Data Minimization | Collect only what is necessary | Broad accumulation of data from multiple registers | ❌ Non-compliant |
| Security & Audit | Strong technical and organizational safeguards | Audit logs, digital signatures, SBU oversight | ✅ Compliant |
| Accountability | Clear sanctions and enforcement | General references to “relevant laws” | ⚠ Weak |
📌 DSS BI consulting+ Conclusions
The law represents a step toward digital integration and centralized data management but lacks sufficient guarantees for citizens’ rights.
The Data Mining Bill framework emphasizes transparency, minimization, and enforceable rights—areas where the Ukrainian law remains underdeveloped.
To achieve GDPR-compliance and alignment with global standards, Ukraine must:
Expand citizens’ rights (erasure, transparency of access),
Define clear sanctions and liability,
Establish an independent supervisory authority.
📢 Summary for Publication: Ukraine is advancing digital governance through the Unified Social Sphere Data System, but the adopted law does not yet meet the standards of GDPR or the Data Mining Bill. Without stronger rights for citizens and clearer accountability, the risks of over-centralization and misuse of personal data remain significant.
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