2025-09-22

On the 2025 Municipal Elections in Georgia

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According to the Law of Georgia on Personal Data Protection, direct marketing is defined as the generation and maintenance of interest in image-related and social topics, as well as the delivery of information to a data subject/voter for the purpose of promotion and/or support.

It should be noted that providing information directly to a voter for the purpose of support - by means of telephone, mail, e-mail, or other electronic communication - constitutes direct marketing. This may be considered a component of pre-election campaigning. For the processing of voters’ data for such purposes, the requirements set out in Article 12 of the Law of Georgia on Personal Data Protection (Processing of data for direct marketing purposes) must be respected:

• Irrespective of the ground for collecting/obtaining data and their accessibility, data may only be processed for direct marketing purposes with the consent of the voter.
• In addition to the name, surname, address, telephone number and e-mail address of the voter, other data shall be processed for direct marketing purposes with the written consent of the voter.
• Prior to obtaining consent and when carrying out direct marketing, the controller/processor shall inform the voter, in clear, simple and understandable language, of his/her right to withdraw his/her consent at any time and of the mechanism/procedure for exercising this right.
• The controller/processor shall ensure that the voter has the possibility to request that the processing of data for direct marketing purposes be terminated in the same form in which the direct marketing is carried out, or to determine other available and adequate means to request the termination of the processing.
• The means to request the termination of data processing for direct marketing purposes shall be simple (e.g., “NO SMS”). In addition, the voter shall be provided with a clear and easily understandable instruction on the use of the means.
• No fee or other restriction shall be imposed on the voter for exercising the right to withdraw consent.
• The voter’s consent to the processing of data for the purpose of direct marketing must be voluntary, specific, and expressed by an active act, which means that the voter must have detailed information, in particular, about:

• The natural person/organization, including a political party, processing their data (for example, phone number, name, address, etc.);
• The means by which a marketing communication will be sent to them (SMS, e‑mail, telephone call);
• The possibility to withdraw the consent they have given at any time.

 

The Personal Data Protection Service of Georgia, as the independent authority supervising the legality of data processing, calls on political parties to respect voters’ rights and to act in full compliance with the requirements of the Law of Georgia on Personal Data Protection when conducting direct marketing.