Data Protection and Privacy 2025

SERBIA Trends and Developments Contributed by: Vladimir Djeric, Katarina Radovic and Lena Petrovic, Mikijelj, Janković & Bogdanović

personal documents and images without con - sent breaches the Law on Public Information and Media, which safeguards individuals’ private lives from unwarranted public exposure. Additionally, these actions also breached jour - nalistic ethical standards. The Code of Jour - nalists Ethics of Serbia emphasises respect for individuals’ privacy and mandates that personal data should not be published without consent. It also advises against discrimination based on personal characteristics and insists on the use of honourable means in data collection. The Commissioner for the Protection of Infor - mation of Public Importance, Milan Marinović, announced that measures would be taken to identify the source of the leaked passport data. However, he noted that his office lacks author - ity over media outlets concerning content pub - lished for public information purposes. He sug - gested that the affected students could request information from the Ministry of Internal Affairs regarding the data leak and, if unsatisfied with the response, file a complaint with the Commis - sioner’s office. Personal Data Protection Strategy 2023-2030 In August 2023, the government of the Republic of Serbia adopted the Personal Data Protection Strategy for the period from 2023 to 2030. The three specific goals defined in the new Strategy are set out below. Improvement of functional mechanisms for personal data protection The fulfilment of this goal, among other things, implies the amendment of the legislative frame - work, and above all the (long overdue) amend - ment of the Personal Data Protection Act in order to clarify insufficiently clear provisions and mechanisms that do not exist in the domestic

legal system. The Strategy raises the possibility that the Commissioner be vested with compe - tence to impose administrative measures, includ - ing penalties, similar to those already available to the Serbian Competition Commission (and already exercised by the data protection authori - ties in the EU). Further, it is considered that the amounts could be higher than the maximum RSD2 million prescribed at the moment (around EUR17,000) and should go in the direction of the fines prescribed by the GDPR (EUR20 million or 4% of realised revenues). Other planned measures include the establish - ment of regional offices of the Commissioner, an increase in the number of specialised persons dealing with data protection and in the number of operators who have adopted internal acts in this area, as well as the appointment of new rep - resentatives of foreign operators in Serbia. Further raising of awareness of the importance of personal data protection and ways of exercising rights This goal includes the education of controllers and decision-makers, and the training of pub - lic administration employees in the field of per - sonal data protection, as well as the education of judges and prosecutors. On the other hand, the importance of the public’s awareness of their rights is also recognised, and the introduction of subjects in this field at different levels of formal education, as well as the education of teachers and professors. Improvement of the personal data protection system during the development

and application of information and communication technologies in the digitisation processes

The strategy recognises the impact of new tech - nologies on personal data protection. The devel -

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