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PROTECTION OF PERSONAL DATA IN THE DIGITAL ECONOMY IN
UZBEKISTAN: LEGAL PROBLEMS AND SOLUTIONS
Jumayev Sanjar
is a 2nd year student at
Karakalpak State University named after Berdak.
A. Gulimov
Scientific Advisor: Doctor of Law
https://doi.org/10.5281/zenodo.15378953
Abstract:
This article analyzes the legal problems of personal data
protection in the digital economy in Uzbekistan and offers practical solutions.
The study examined the effectiveness of the Law “On Personal Data Protection” ,
its compliance with international standards (GDPR), and the practical
application of the legislation based on statistical data for 2022–2025. The results
showed the lack of clear mechanisms in the law, weak law enforcement, and
shortcomings in adapting to global requirements. The discussion made
proposals such as establishing a special supervisory div, regulating cross-
border data exchange, and strengthening fines. The study serves as a roadmap
for ensuring citizens' rights in the digital environment and improving legislation.
Keywords:
personal data, digital economy, legal analysis, GDPR,
cybersecurity, Uzbek legislation, data protection, cross-border exchange,
supervisory div, digitalization.
Introduction
The rapid development of the digital economy has dramatically increased
the value of personal data and the risks to it in modern society . The number of
Internet users in Uzbekistan is expected to exceed 30 million by the beginning of
2025, and the transition of e-commerce and public services to digital platforms
has made the issue of personal data protection an urgent problem . This process
not only expands economic opportunities, but also creates new legal and
technological problems that threaten the privacy of citizens. In particular, the
illegal distribution of personal data, the increase in cybercrime, and gaps in the
legislation require in-depth analysis and reforms in this area.
The issue of personal data protection in Uzbekistan is regulated by the Law
“On Personal Data Protection”, adopted in 2019. However, the practical
application of this law and its compliance with the requirements of the modern
digital environment raise many questions. For example, insufficiently developed
mechanisms for preventing data disclosure and enforcing the law, as well as
limited opportunities for citizens to exercise control over their data, are
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highlighted as significant shortcomings. At the same time, international
experience, in particular standards such as the European Union's General Data
Protection Regulation (GDPR) , serve as an important yardstick in assessing the
effectiveness of Uzbek legislation.
The purpose of this study is to analyze the legal framework for the
protection of personal data in the digital economy of Uzbekistan, identify
existing problems and propose practical solutions to them. In the process of
research, an answer to the following main question is sought: To what extent
does the current legislation of Uzbekistan meet the modern requirements for the
protection of personal data in the digital environment and what measures
should be taken to improve it? This question reflects not only legal theory, but
also the urgent needs for ensuring the rights of citizens in the practical sphere.
The scientific significance of the study is that it conducts an in-depth
analysis of an area that is little studied in the context of Uzbekistan, but is
becoming increasingly important within the framework of the digitalization
strategy. At the same time, the topic provides an opportunity for comparative
analysis with international standards, which allows not only academic
discussions, but also the development of practical proposals for improving
legislation. The results of this work can serve as a roadmap for state bodies,
business entities and citizens in ensuring security in the digital environment.
Methodology
This study is based on a comprehensive approach to assessing and
identifying ways to improve the legal framework for personal data protection in
Uzbekistan in the digital economy. The main question presented in the
introduction — the compliance of legislation with modern requirements and the
need for its development — determines the main direction of the methods used
in this section. In the research process, such methods as analysis of regulatory
legal acts, comparative comparison with international standards, and study of
practical data are used together.
At the first stage, a legal analysis of the Law of Uzbekistan “On Personal
Data Protection” and related secondary regulatory documents is carried out. In
this process, the structure of the law, possible mechanisms of application, and
clearly defined liability measures are carefully considered. The analysis is based
on an inductive method: first, individual articles are studied, and then a
conclusion is drawn about their overall effectiveness. This approach ensures
accuracy in identifying gaps in the legislation.
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In the second stage, the General Data Protection Regulation (GDPR) of the
European Union is chosen as the main benchmark for comparing Uzbek
legislation with international experience. The comparative analysis process
examines the similarities and differences between the two systems, in particular,
citizens' rights, data security measures, and enforcement mechanisms . This
method allows assessing the compliance of the legislation with global
requirements and serves to identify solutions that can be adapted for
Uzbekistan.
In the third stage, for the analysis of practical data, cases related to the
disclosure of personal data in Uzbekistan over the past three years (2022–2025)
are studied . For this, open sources from state bodies such as the Ministry of
Justice, the Ministry of Information Technologies and Communications
Development, as well as statistics on relevant cases in judicial practice are taken
as a basis. Given the limited data, attention is paid to drawing exemplary
conclusions from existing cases.
The use of a combination of qualitative and quantitative methods in the
study increases the depth and objectivity of the analysis. The results obtained at
each stage are coordinated with each other and serve as the basis for further
discussion. This methodological approach allows not only to identify legal
problems, but also to develop practical measures to eliminate them.
Results
During the research, the legal framework of Uzbekistan on personal data
protection, its compliance with international standards and the practical
situation were studied in depth. In this section, the results obtained are
summarized in three main areas and presented in accordance with the general
context: the structure and effectiveness of the legislation, the degree of
compliance with global requirements, and the state of data security in real life.
1. Legal analysis of the legislation
The Law of the Republic of Uzbekistan “On the Protection of Personal Data”
(April 21, 2021, No. O‘RQ-683) was studied as a result of inductive analysis. The
law contains the main norms regulating the collection, storage and use of
personal data. However, one of the significant shortcomings identified is the lack
of clarity of liability mechanisms. For example, the law provides for sanctions for
data security violations in general terms, but does not set clear quantitative or
qualitative limits. This can lead to uncertainties in the application of the law and
reduce the practical effectiveness of the law. At the same time, the law is aimed
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at ensuring the right of citizens to privacy, which is considered a positive step in
this area.
2. Comparative analysis with international standards
A comparative analysis with the General Data Protection Regulation (GDPR)
of the European Union showed that Uzbek legislation has similarities with the
GDPR in terms of general principles for ensuring the confidentiality of personal
data. For example, both documents stipulate the consent of the data subject as a
basic condition. However, unlike the GDPR, the rules for cross-border data
transfers in Uzbek law are not sufficiently detailed. While the GDPR contains
strict conditions for such transfers (for example, an Adequacy Decision), Uzbek
legislation limits this process to a general authorization only. As of March 2025,
according to the Ministry of Information Technologies and Communications of
Uzbekistan, about 15% of international data exchange in the country was
carried out through foreign platforms, but weak legal control over this process
was identified . This indicates the need for additional reforms to adapt to the
demands of the global digital economy.
3. Practical data and statistical analysis
Cases related to the disclosure of personal data during 2022–2025 were
analyzed based on data from the Ministry of Justice and judicial practice.
According to open sources of the State Statistics Committee of the Republic of
Uzbekistan, 127 cases of personal data breaches were officially registered in
2023, which is 18% more than in 2022. At the same time, only 12% of cases in
judicial practice (15 cases) ended with legal punishment, and the rest were left
without administrative measures. These statistics confirm the existence of
serious problems in the practical application of the law and the effectiveness of
law enforcement agencies . For example, in 2024, in the case of the disclosure of
data of 50 thousand users on a large online platform in Tashkent, only fines
were applied, but no systematic solution was developed. These cases, along with
gaps in the law, also demonstrate the weakness of the technological
infrastructure .
Conclusion and overall assessment
The results of the analysis show that, although the legal framework of
Uzbekistan in the field of personal data protection is able to meet the general
requirements of the modern digital environment, there are significant
shortcomings in practical implementation and full compliance with international
standards. The lack of clear mechanisms in the legislation, the weakness of
liability measures, and technical limitations in ensuring data security emphasize
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the need for reforms in this area. At the same time, the existing law provides
certain opportunities for protecting citizens' privacy, which can serve as a basis
for developing the system in the future.
Discussion
The results of the study clearly demonstrated the legal and practical
problems in the field of personal data protection in Uzbekistan: the lack of clear
mechanisms in the legislation, ineffective law enforcement, and insufficient
adaptation to the requirements of the global digital economy. This situation not
only threatens the privacy rights of citizens, but can also negatively affect the
success of the digitalization strategy. In this context, this section discusses the
implications of the identified problems and proposes new approaches to
overcome them.
First, legislative uncertainties undermine the balance of trust in the digital
environment . For example, due to the lack of clear accountability measures,
sanctions for organizations that violate data security often remain symbolic.
This not only undermines the reputation of the legal system, but is also
ineffective in encouraging business entities to comply with security standards.
Taking into account international experience, the GDPR’s penalty mechanisms
(up to 4% of annual revenue) could be adapted for Uzbekistan . Such measures
would not only strengthen law enforcement, but also force companies to invest
in data security.
Secondly, legal loopholes in cross-border data exchange are an obstacle to
Uzbekistan’s global economic integration. As the results show, about 15% of
data exchange via foreign platforms remains uncontrolled. This situation not
only poses a threat to cybersecurity, but also creates distrust in international
cooperation. In this regard, it is necessary to include a special section “on
international data transfers” in the legislation. This section may include rules
such as the formation of a list of safe countries and mandatory audits before
data transfers . Such an approach will position Uzbekistan as a reliable partner
in the international digital economy.
Thirdly, practical statistics have shown that violations of personal data do
not reach the courts (only 12% of cases are punished). To eliminate this
situation, it is proposed to establish a special supervisory div for the
protection of personal data . This div can perform the functions of not only
monitoring violations, but also advising citizens on their rights and promptly
considering complaints. For example, the model of the Information
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Commissioner’s Office (ICO) in the UK could be adapted for Uzbekistan, as
according to the annual reports of this organization, 85% of complaints are
resolved within a month. Such a structure would increase the efficiency of law
enforcement and strengthen citizens’ trust in the law .
As a new direction for future research, the issue of ensuring the security of
personal data through digital platforms (for example, MyGov.uz or Telegram)
could be studied . Currently, these platforms are widely used in Uzbekistan, but
their data protection standards have not been sufficiently analyzed. At the same
time, the possibilities of introducing cybersecurity solutions based on artificial
intelligence could also become an important topic of research in the future .
These approaches open up new opportunities not only technologically, but also
legally.
The proposed solutions will serve to strengthen Uzbekistan's participation
in the digital economy. The security of personal data will be ensured by
improving legislation, developing international cooperation, and strengthening
practical control . These measures will not only modernize the legal system, but
also help increase citizens' trust in the digital environment.
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