What happens during a personal data law inspection and how do you help?

The inspector asks you to confirm that personal data protection measures are in place: who is appointed as responsible, which documents and logs are kept, whether the vulnerabilities found have been closed. KEMEL.TECH prepares a document pack for each legal entity, checks it against the inspection checklist and the evidence inventory, and, when a request arrives, prepares the response and documents within 24 hours. Our specialist takes part in the inspection as a technical specialist under a power of attorney, explains the measures taken to the inspector and helps with objections to the inspection act. We support the inspection. Representation in court and in administrative offence cases is handled by a partner law firm.

What category is my company?

Count the total number of unique people whose personal data is held across all your systems: customers, employees, candidates, subscribers. This is not an annual figure. Up to 10,000 is small, 10,000 to 500,000 is medium, 500,000 and above is large. If you process restricted-access personal data, the category goes up one level. For a group of companies the category is determined for each legal entity separately. The calculator on the “Data law” page gives an approximate result in 5 minutes, and KEMEL.TECH helps you determine the category and draw up a measures plan for free. The calculation is not legal advice.

What is the KEMEL platform and what do I need to install?

The KEMEL platform is a cabinet where you see alerts, the findings register, personal data law logs and your inspection readiness status. An agent (Fluent Bit and osquery) is installed: it works over an outbound mTLS connection on port 443, so no inbound ports need to be opened. The agent takes 1 day to install: we install it or you do it yourself. The pilot lasts 14 days: first we run a pentest and find out what vulnerabilities you have, then we switch on the agent, connect sources and mask personal data, after which we record findings and tune the rules to your systems. At the end you receive a pilot report.

Where are my data and logs stored?

IP addresses, logins, full names and sometimes IINs end up in security logs, and these are personal data. The law requires personal data to be stored in a database on the territory of the Republic of Kazakhstan (Art. 12 of Law No. 94-V “On Personal Data and Their Protection”). The KEMEL platform runs in a data center in Kazakhstan (SaaS) or in your own perimeter (on-prem), and IINs, phone numbers and e-mails are masked before they are written. Not legal advice.

How much does the support cost?

KEMEL GUARD is a subscription with the platform, specialists and personal data law documents. GUARD Start is from 250,000 ₸ per month for small companies (up to 10,000 people in the database). GUARD Pro is from 500,000 ₸ per month for medium companies (10,000 to 500,000 people) and includes KEMEL WATCH monitoring. GUARD Ultra is for large companies (500,000 people and above) and holdings, priced individually. GUARD Gov is for government bodies, priced individually. The final price depends on scope and is fixed in the contract. Billed separately: Red Team KEMEL BREACH from 1,200,000 ₸, a duty shift by agreement.

What is a pentest in plain words?

A pentest (penetration test) is a security check in which specialists, under a contract with the system owner, try to break into the systems the way a real attacker would. The goal is to find weak spots before attackers do, confirm them without harming data or service operation, and explain how to fix them. As a result the client receives a report describing each vulnerability, its severity and recommendations.

How does payment only for vulnerabilities found work?

At KEMEL.TECH (Kazakhstan) the client pays only for vulnerabilities actually found, at a fixed rate. If no vulnerabilities are found, you get a “perimeter clean” PDF report for free. There is no prepayment, and duplicates of the same vulnerability are not billed twice. The price of each finding is set by its severity on the CVSS scale: from 15,000 ₸ for LOW to 600,000 ₸ for CRITICAL.

Is pentesting legal in Kazakhstan?

Yes, pentesting in Kazakhstan is legal with the written permission of the resource owner (Authorization Letter). Without such permission it is unlawful access to information under Art. 205 of the Criminal Code of Kazakhstan. KEMEL.TECH works strictly within the law: under a contract with a clear scope and an NDA, in line with the Law of Kazakhstan “On Personal Data and Their Protection” No. 94-V.

What should we do if a breach occurs?

Notify the authorized body, the Information Security Committee of the Ministry of Digital Development, Innovation and Aerospace Industry, within one business day of discovery. The notification states the contact of the responsible person, the measures taken and the data of affected people: full name, IIN or phone number. Citizens are then notified by the e-government operator. The sequence of actions: detection, assessment (what leaked and whose data), notification, measures and a report. KEMEL.TECH prepares a procedure and a notification template in advance, and during an incident joins from 4 hours and helps prepare the notification on time.

Do you work with government bodies?

Yes. For government bodies, the quasi-public sector and owners of critical ICT infrastructure there is GUARD Gov: the KEMEL platform is deployed on-prem in the customer's perimeter, and data does not leave your perimeter. It includes preparation for the new information security requirements, integration and exports for working with NCIS, pentest and Red Team, personal data law logs and training of in-house specialists. We prepare you for compliance testing; the testing itself is performed by an authorized organization. To request a technical specification, use the form on the “Public sector” page.

Is a pentest required by the personal data law?

For large operators (from 500,000 people) the law provides for a security assessment and penetration testing, as well as an independent audit. For small companies a pentest is not required by law. For medium ones, a vulnerability analysis is mandatory.

Who carries out inspections under the personal data law?

Inspections are carried out by the authorized body. Liability for violations is provided by Article 79 of the Code of Administrative Offenses of Kazakhstan.

From what date do the new requirements apply?

Personal data protection measures under Article 25-1 apply from 21.09.2026. For restricted-access data, the transition to ST RK 1073-2025 is from 01.01.2027.

Personal Data Law of Kazakhstan from 21.09.2026: what is mandatory

KEMEL.TECH · Updated October 16, 2026

Personal data protection measures in Kazakhstan depend on the operator's category, which is determined by the total number of unique people in its digital assets: up to 10,000 — small, from 10,000 to 500,000 — medium, from 500,000 — large. If restricted-access data is processed, the category goes up by one level. In case of a breach, the authorized body must be notified within one business day.

How to determine your company's category

Count the total number of unique people whose personal data is in all your systems: customers, employees, candidates, subscribers. This is not an annual figure but the total number of personal data subjects.

For a group of companies, the category is determined separately for each legal entity. The calculator on the “Personal Data Law” page gives an approximate result in 5 minutes. It is not legal advice.

Small: up to 10,000 people.
Medium: from 10,000 to 500,000 people.
Large: from 500,000 people.
Restricted-access data raises the category by one level.

What each category requires

Small: a responsible person, internal documents, access control, logs, backups, antivirus, secure channels. A pentest is not required by law.
Medium: everything from the basic measures, plus vulnerability analysis, periodic employee training, an incident response procedure and internal compliance control.
Large: everything from medium, plus a security assessment, penetration testing, an independent audit of personal data protection measures and cybersecurity event monitoring.

Restricted-access data

For such data, collection and processing are allowed only on digital assets in the Republic of Kazakhstan, and cryptographic protection follows ST RK 1073-2007 (from 01.01.2027 — ST RK 1073-2025).

Security logs may also contain personal data: IP addresses, logins, full names, sometimes the IIN. So when connecting monitoring it is important to mask such fields before they are written.

Regulatory framework

Law of Kazakhstan No. 94-V “On Personal Data and Their Protection”, Article 25-1 (as amended by Law No. 326-VIII of 24.06.2026).
Rules for implementing personal data protection measures (order No. 179/НҚ as amended by Ministry order No. 534/НҚ).
Rules for notification of a personal data security breach (order No. 481/НҚ).
Liability — Article 79 of the Code of Administrative Offenses of Kazakhstan.

Where to start

Count the number of personal data subjects and determine the category.
Appoint a person responsible for personal data protection and approve internal documents.
Set up logs: access, incidents, backups.
Prepare a breach response procedure and a notification template.
For medium and large operators: run a vulnerability analysis or pentest and train employees.

Frequently asked questions

Is a pentest required by the personal data law?: For large operators (from 500,000 people) the law provides for a security assessment and penetration testing, as well as an independent audit. For small companies a pentest is not required by law. For medium ones, a vulnerability analysis is mandatory.
Who carries out inspections under the personal data law?: Inspections are carried out by the authorized body. Liability for violations is provided by Article 79 of the Code of Administrative Offenses of Kazakhstan.
From what date do the new requirements apply?: Personal data protection measures under Article 25-1 apply from 21.09.2026. For restricted-access data, the transition to ST RK 1073-2025 is from 01.01.2027.

Find out your category for free