Law note · Kyrgyzstan

Digital Code, special categories of personal data

cite Digital Code, Law No. 178, Art. 80 stage RECENT in force 7 months effective 2026-02-06 kind Sensitive categories binds public and private bodies reviewed 2026-08-29

What it requires

  • An app that processes biometric data for the digital identification of a Kyrgyzstani data subject, including a voiceprint or faceprint, must satisfy one of Art. 80(2)'s narrow lawful grounds before processing; such processing is prohibited by default otherwise. The Code itself supplies no illustrative list of biometric modalities for this general provision.

When LexLint raises it

  • processes_biometrics
  • processes_voice
  • crawls_web
  • trains_models

What we found

Art. 80(1), read in full and confirmed word for word against the official portal in a reviewer pass, prohibits processing by default: data revealing racial or ethnic origin, political views, religious or philosophical beliefs, or trade-union membership; genetic information; biometric data for the digital identification of a natural person; and data concerning health, sex life, or sexual orientation.

Art. 80(2) lifts the prohibition for contract necessity, explicit statutory authorization, vital-interest necessity, data the subject has explicitly made public, medical or public-health purposes, and (in part) membership processing by an association or religious organization.

No definition of biometric data as a general term was found anywhere in the official Code text (confirmed by a reviewer-pass search for the root "биометрич" across the whole document, which surfaces only Art. 48's state-system provisions and Art. 80(1)(3)'s bare category name); the only enumerated biometric-modality list in the Code is Art. 48(3)'s narrower, government-identification-system-specific list, confirmed at the official source to read exactly: digital facial image, papillary-pattern fingerprints of both hands, and handwritten signature, naming no voice modality, which should not be read as governing this general provision.

Primary source

official government portal
Centralized Bank of Legal Information of the Kyrgyz Republic (cbd.minjust.gov.kg), which serves this page's text only to a rendering tier: a plain HTTP fetch of this same URL returns a 1,961-character JavaScript shell with zero hits for any Chapter 11 term, while the crawler's STEALTH_PLUS rendering tier returns the full 657,172-character document confirmed directly against this URL

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