Four questions. The result appears on this same page.
1/4
How many different people are in your databases in total: customers, employees, candidates, subscribers? Count the total number, not the annual growth.
This calculation is indicative only and is not legal advice.
What we take on
Eight steps from the category opinion to the leak notification.
1
We determine the category: a written opinion for each legal entity.
2
We find and document: pentest, vulnerability analysis, monitoring; every finding goes into a register with a date, severity, owner and deadline.
3
We give recommendations: your team implements them, we do not change your systems.
4
We verify with a retest: a report with the date, method and residual risk.
5
We keep the logs that the law requires and the inspector will ask for.
6
We prepare you for the inspection: check against the inspection checklist, an inventory of evidence, a package per legal entity.
7
We support the inspection: we prepare responses to requests, take part as a technical specialist under power of attorney, explain the measures taken to the inspector and help with objections to the inspection report.
8
In case of a leak: we step in within 4 hours and prepare the notification to the Information Security Committee of the Ministry of AI and Digital Development within 1 business day.
Logs and documents
What is recorded and for whom it is mandatory. Every document has a template.
Log or documentWhat it recordsMandatory forSample
Operator category opinionNumber of data subjects, restricted-access data, categoryThe basis of all measuressample
Register of digital assets and data flow mapSystems and databases where personal data is stored, ownersMedium, largesample
Monitoring, vulnerability analysis and everything the law requires from mid-size companies
from500,000₸ / mo
SIEM
KEMEL platform and KEMEL WATCH monitoring
Security team
Specialists triage alerts and write rules
What is included
Documents and logs under the personal data law
Everything in GUARD Start
KEMEL WATCH: monitoring, alerts, rules tuned to your systems
Release checks
Vulnerability register with retests
Large
from 500,000 people in the database
GUARD Ultra
Everything turnkey: from monitoring to legal support
Individually negotiated
SIEM
KEMEL platform with all modules, turnkey
Security team
Dedicated specialist, vCISO and legal support
What is included
Documents and logs under the personal data law
Everything in GUARD Pro
Dedicated specialist and vCISO: security strategy and management reporting
Pentest and Red Team on an annual plan
Incident response and breach notification preparation
Framework agreement and a separate evidence pack for each legal entity
Group executive dashboard
Legal support via a partner law firm: inspections, objections to the act, representation
Public sector
agencies and quasi-public sector
GUARD Gov
Government bodies, local authorities, quasi-public sector, critical ICT infrastructure owners
Individually negotiated
SIEM
KEMEL platform on-prem in your perimeter
Security team
Specialists configure and train your staff
What is included
Documents and logs under the personal data law
On-prem platform inside the customer's perimeter
Preparation for new security requirements
Integration with NCIS
Pentest and logs under the personal data law
Staff training
Personal data law questions
What happens at a personal data inspection and how do you help?
The inspector requests documents and proof of the measures taken. We assemble a package per legal entity in advance: the category opinion, the findings register with retest reports, the logs and the leak response procedure. During the inspection our specialist takes part as a technical specialist under power of attorney, prepares responses to requests and helps with objections to the inspection report.
What is my 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. Up to 10,000 — small; from 10,000 to 500,000 — medium; from 500,000 — large. If you process restricted-access personal data, your category goes up one level. The calculator above gives an indicative result in 5 minutes.
Is a pentest mandatory under the personal data law?
From 21 September 2026, penetration testing, security assessment and an independent audit of personal data protection measures are mandatory for large operators, from 500,000 unique data subjects. Medium operators must run vulnerability analysis, train employees, approve an incident response procedure and carry out internal control. For small operators (up to 10,000) the law does not require a pentest.
What is restricted-access data?
This is information whose access is restricted by the legislation of Kazakhstan. The requirements for it are stricter: such data may be collected and processed only on servers and in systems located in Kazakhstan, and must be protected by encryption of at least level 3 under the national standard ST RK 1073-2007 (from 1 January 2027, ST RK 1073-2025). The company's category also goes up one level.
What should we do if a leak occurs?
From the moment of discovery, the company has one business day to notify the authorized body: the Information Security Committee of the Ministry of AI and Digital Development. The notification states the contact of the responsible person, the measures taken and the data of those affected: full name, IIN or phone number. The citizens themselves are then notified by the e-government operator. We step in within 4 hours and help prepare the notification.
What fines apply?
Under Art. 79 of the Administrative Offenses Code of Kazakhstan, for failing to apply personal data protection measures the fine is from 300 to 600 MCI (≈1.3–2.6 million ₸); if it led to data loss, up to 2,000 MCI (≈8.65 million ₸). MCI is the monthly calculation index. The fine depends on the size of the business.
Where are my data and logs stored?
IP addresses, logins, full names and sometimes IINs all end up in security logs. 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). The KEMEL platform runs in a data center in Kazakhstan or in your own environment, and IINs, phone numbers and e-mails are masked before they are written.
How much does support cost?
GUARD Start: from 250,000 ₸ per month for small companies (up to 10,000 people in the database). GUARD Pro: from 500,000 ₸ per month for medium companies (from 10,000 to 500,000 people), includes KEMEL WATCH monitoring. GUARD Ultra: for large companies (from 500,000 people) and holdings, priced individually. GUARD Gov: for government bodies, priced individually. The final price depends on scope and is fixed in the contract.
Do you work with government bodies?
Yes. For government bodies and the quasi-public sector there is GUARD Gov: a platform inside the customer's environment, preparation for the new information security requirements, integration with the NCISC (НКЦИБ), pentest, personal data law logs and staff training. For the public sector →
Sources: Law of Kazakhstan No. 94-V "On Personal Data and Their Protection" (including Art. 12 and Art. 25-1, as amended by Law No. 326-VIII of 24.06.2026); Rules for personal data protection measures (Order No. 179/НҚ as amended by Order No. 534/НҚ of the Ministry of AI and Digital Development, from 21.09.2026); Rules for notifying of personal data security breaches (Order No. 481/НҚ); Rules for collecting and processing personal data (Order No. 556/НҚ, from 02.10.2026); Art. 79 of the Administrative Offenses Code of Kazakhstan. The information on this page is not legal advice.
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