The Argentine Social Security Administration Implemented New Data Privacy and Access to Public Information Policies

On November 11, 2018, the Argentine National Social Security Administration ( the “ANSES” after its Spanish acronym) enacted Resolution No. 204/2018 (the “Resolution”), which implements new data privacy and access to public information policies, alongside a policy for the interchange of information with the controlling authorities.
 

The Resolution approved three sets of policies: (i) Personal Data Protection Policies, (ii) Access to Public Information Policies, and (iii) Policies for the Interchange of Information with Controlling Authorities (together, the “Policies”).
 

The ANSES also designated the authorities in charge of executing the institutional arrangements with other public entities, which must be drafted pursuant to the terms and conditions of the Policies. Such authorities will also be in charge of approving model clauses for confidentiality agreements and statements of the ANSES.
 

The Resolution determined that the Chief of the Administrative Requirement Coordination Directorate of the ANSES must be the ANSES’s Access to Public Information Responsible Officer.
 

The Resolution was passed sometime after the ANSES executed a Framework Agreement for Cooperation between with the Secretariat of Public Communications. Said agreement had received some criticism regarding its compliance with Personal Data Protection Law No. 25,326 (see “The President’s Chief of Staff approved an agreement with the Argentine Social Security Administration for the assignment of personal data to the Secretariat of Public Communications”, dated August 17, 2016).
 

This Resolution has been issued to comply with the legal requirements determined under Personal Data Protection Law No. 25,326 and Access to Public Information Law No. 27,275.