Since the EU General Data Protection Regulation (GDPR) came into effect in 2018, businesses operating within the European Union have faced strict data protection obligations. For international companies expanding into Central and Eastern Europe, understanding data protection in Hungary is no less important.
Hungary’s data protection framework combines the directly applicable GDPR with strong national enforcement, creating a regulatory environment where compliance requires both legal awareness and practical preparedness.
How is GDPR implemented and enforced in Hungary?
GDPR implementation in Hungary is grounded in the country’s national Data Protection Act (Act CXII of 2011), which predates the GDPR but has since been harmonized to align with EU standards. The act complements the GDPR by defining national-level responsibilities, enforcement mechanisms, and the powers of the National Authority for Data Protection and Freedom of Information (NAIH).
The NAIH plays a central role in interpreting GDPR rules in Hungary, investigating data breaches, and imposing fines. Recent enforcement actions have shown that the authority takes a proactive stance, particularly when it comes to insufficient consent management, unlawful data transfers, or the misuse of personal data for marketing purposes.
In some cases, fines have reached tens, or even hundreds of millions of forints, underscoring how seriously Hungary treats compliance. For international companies processing data of Hungarian residents, it’s not enough to follow EU-level GDPR principles: they must also understand how Hungarian authorities interpret and apply them in practice.
Key requirements for data protection compliance in Hungary
Ensuring data protection compliance in Hungary involves several essential steps that every organization — especially foreign ones — should take:
- Appoint a Data Protection Officer (DPO): Companies involved in large-scale or sensitive data processing are legally required to designate a DPO who can oversee GDPR compliance and liaise with the NAIH.
- Maintain detailed records of data processing activities: Transparency is a cornerstone of GDPR regulations in Hungary. Companies must document how and why they process personal data and make this information available upon request.
- Ensure data security and technical safeguards: Hungarian law emphasizes adequate protection of IT systems. Encryption, pseudonymization, and access control measures are strongly encouraged.
- Handle data breaches swiftly: In Hungary, data breaches must be reported to the NAIH within 72 hours. Companies should also have a communication plan to notify affected individuals if their personal information has been compromised.
- Review data transfers outside the EU: Businesses transferring data to non-EU countries must use EU-approved safeguards such as Standard Contractual Clauses (SCCs) or rely on adequacy decisions.
Each of these areas requires careful implementation, often with the guidance of a GDPR specialist lawyer in Hungary, who can help translate complex legal obligations into practical measures.
Why should international companies hire a GDPR specialist lawyer in Hungary?
For global organizations entering or operating in the Hungarian market, understanding local data protection nuances can be challenging. Even when a company already has a European data privacy policy, local adaptations are regularly required to reflect Hungarian regulations, language requirements, and enforcement practices.
A GDPR specialist lawyer in Hungary can provide essential guidance in this process.
These legal experts assist with:
- drafting data protection policies,
- conducting Data Protection Impact Assessments (DPIAs),
- representing clients in front of the NAIH,
- and ensuring that marketing practices, employee monitoring, and cloud-based data storage comply with national standards.
The GDPR specialist lawyers at Jalsovszky have also dealt with cases like this, advising international companies on how to remain compliant when processing personal data of Hungarian individuals. Their work demonstrates that compliance is not just a legal checkbox: it is part of a company’s overall risk management and reputation strategy.
The role of a data protection lawyer in Hungary
Beyond advising on day-to-day compliance, a data protection lawyer in Hungary provides vital support during audits or investigations.
The NAIH frequently requests documentation to prove that companies meet GDPR requirements. Having a legal expert prepare and maintain these materials can save businesses from administrative penalties and reputational damage.
Moreover, a data protection lawyer can assist with internal training for staff who handle personal data, which is an increasingly important requirement under the Hungarian GDPR implementation. Employees must understand how to identify and respond to privacy risks, as even minor mistakes can lead to significant regulatory consequences.
Recent trends in GDPR enforcement in Hungary: what kind of issues attract the scrutiny of authorities?
In recent years, Hungary has followed broader EU trends toward more stringent enforcement. The NAIH’s decisions often mirror those of other European data protection authorities, focusing on accountability and the principle of “privacy by design.”
Common issues that attract scrutiny include:
- Misuse of employee data, such as GPS tracking or excessive CCTV surveillance.
- Non-transparent cookie policies and website tracking practices.
- Inadequate security measures leading to data leaks.
As cybersecurity becomes an increasingly important part of compliance, Hungarian regulators also pay close attention to IT infrastructure and how companies protect sensitive data. This aligns with the growing emphasis on privacy and cybersecurity among leading Hungarian law firms, which often recommend ongoing audits and proactive risk assessments.
How to stay compliant? GDPR best practices for international businesses in Hungary
For multinational companies, staying compliant with GDPR in Hungary requires more than a one-time legal review. Instead, it should be treated as an ongoing process that evolves alongside technology and regulation.
Some practical steps include:
- Conducting annual compliance audits with a GDPR specialist lawyer in Hungary.
- Updating privacy policies regularly to reflect changes in processing activities.
- Training employees on data handling and reporting procedures.
- Implementing technical solutions that support data minimization and secure processing.
Taking these proactive measures demonstrates accountability, which is a key principle of GDPR in Hungary. It also helps businesses maintain strong relationships with both regulators and customers.
