Law note · Sri Lanka

Personal Data Protection Act, comprehensive regime and lawful basis

cite Personal Data Protection Act, No. 9 of 2022, as amended by Act No. 22 of 2025, Schedule I, ss.5, 18(1), 20-25 stage IN FORCE in force since 2025-03-18 kind Comprehensive regime binds public and private bodies reviewed 2026-08-29

What it requires

  • An app that collects, uses, or discloses the personal data of an individual in Sri Lanka, including a voiceprint or faceprint, must have a lawful basis under Schedule I, ordinarily consent, contract necessity, or a legitimate interest satisfying a balancing test, and must give a data subject a way to seek review of a decision based solely on automated processing that has created or is likely to create an irreversible and continuous impact on their rights.

When LexLint raises it

  • crawls_web
  • trains_models
  • generates_content
  • deploys_chatbot
  • automated_outreach
  • high_risk_decisions
  • processes_voice
  • processes_biometrics

What we found

Lawful basis, referenced by s.5 against Schedule I, follows a General Data Protection Regulation (GDPR) Article 6 shape: consent, contract necessity, legal obligation, vital interests, a public-interest task, or legitimate interest subject to a balancing test. Controller and processor duties are allocated at ss.20-25, with processors bound by written instructions and sub-processor flow-down duties.

Section 18(1) gives every data subject the right to request review of a decision based solely on automated processing that has created or is likely to create an irreversible and continuous impact on their rights and freedoms, subject to listed exceptions (authorized by law, authorized by the Authority, based on consent, or contract necessity). In force since 18 March 2025.

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