Uruguay Regulatory Compliance Services

Organizations should review their processing activities against the current consolidated legal framework, including relevant provisions introduced by Law No. 19,670 and applicable implementing rules.

Key compliance activities may include:

• Maintaining an inventory of personal data processing activities.
• Defining the purposes and legal grounds for processing.
• Preparing appropriate privacy notices and disclosures.
• Obtaining consent where required and documenting applicable exceptions.
• Establishing procedures for access, rectification, updating, inclusion, and deletion requests as applicable.
• Protecting sensitive personal data with suitable safeguards.
• Implementing data retention and secure deletion practices.
• Reviewing processor agreements and third-party access.
• Assessing applicable personal database registration requirements.
• Establishing privacy accountability and incident management processes.

These provisions address operational aspects of data protection, including security, accountability, and the assessment of risks associated with processing activities. Depending on the organization and the processing involved, additional requirements may apply to privacy governance and documentation.

Organizations should assess:

• Privacy policies and internal procedures.
• Data processing records and database registration obligations.
• Risk assessment and privacy impact assessment requirements where applicable.
• Allocation of privacy responsibilities.
• Security controls and incident response procedures.
• Data retention, deletion, and access management.
• Vendor governance and processor arrangements.
• Evidence of compliance and periodic review.

The URCDP has issued decisions and guidance on transfer requirements, including adequacy, contractual safeguards, transparency, and authorization procedures. Recent regulatory developments in 2026 reinforce the importance of reviewing the current requirements before implementing cross-border data arrangements.

Uruguay is also one of a small number of countries recognized by the European Commission as providing an adequate level of personal data protection, under Commission Decision 2012/580/EU of 21 August 2012. That recognition was adopted under the EU's earlier data protection directive and continues to apply unless it is amended, replaced, or repealed, so organizations relying on it should confirm its current status. In practice it means personal data can generally be transferred from the EU to Uruguay without requiring additional transfer safeguards, which can simplify arrangements for European groups operating locally.

Organizations using international cloud platforms, outsourced services, global databases, or overseas group companies should assess:

• The countries in which personal data is stored and accessed.
• The parties' roles as controllers, processors, or other relevant participants.
• Whether an arrangement constitutes a transfer or another type of processing.
• The destination's recognized adequacy status.
• Applicable exceptions and permitted transfer mechanisms.
• Whether prior authorization or other regulatory steps are required.
• Contractual safeguards and recipient obligations.
• Transparency requirements concerning international data flows.

Depending on the incident and the applicable rules, organizations may have obligations to notify the relevant authority and, where required, affected individuals. Reporting criteria and deadlines should be verified against the provisions applicable to the organization and incident.

A practical compliance program may include:

• Information security risk assessments.
• Access controls and authentication procedures.
• Protection against unauthorized disclosure, alteration, or loss.
• Incident detection, escalation, and response processes.
• Procedures for assessing the impact of personal data incidents.
• Regulatory notification workflows where required.
• Evidence preservation and incident documentation.
• Third-party security and vendor oversight.
• Business continuity and recovery planning.

Organizations should assess the law's relevance alongside applicable cybersecurity policies, sector-specific rules, and contractual security commitments.

Compliance support may include:

• Identifying relevant cyber risks and legal obligations.
• Reviewing access management and security procedures.
• Establishing incident escalation and investigation workflows.
• Assessing supplier and third-party security risks.
• Coordinating cybersecurity and privacy incident response.
• Maintaining appropriate records and supporting evidence.
• Reviewing security governance and accountability.

A website compliance review may include:

• Inventorying cookies and tracking technologies.
• Identifying personal data collected and the purposes of processing.
• Reviewing privacy notices and tracking disclosures.
• Assessing consent and other applicable legal requirements.
• Reviewing advertising and analytics vendor arrangements.
• Establishing appropriate retention and access controls.
• Ensuring that actual website behavior matches published privacy information.

Relevant compliance areas may include:

• Accurate product and service descriptions.
• Pricing and other consumer-facing disclosures.
• Advertising and commercial representations.
• Online purchasing and contracting processes.
• Customer complaints and claims handling.
• Applicable withdrawal, cancellation, or refund rights.
• Terms and conditions for digital services.
• Third-party marketplace and service-provider arrangements.

Compliance reviews may cover:

• Electronic contracting workflows.
• Electronic signatures and authentication processes.
• Document integrity and recordkeeping.
• Retention and retrieval of electronic records.
• Digital transaction evidence.
• Internal procedures for approving and signing agreements.
• Vendor arrangements for electronic signature platforms.

AI-related governance should be proportionate to the nature of the system, the data involved, the intended use, and the risks associated with deployment.

Relevant measures may include:

• Maintaining an inventory of AI systems and use cases.
• Assessing personal data used to develop or operate AI systems.
• Documenting processing purposes and system limitations.
• Reviewing transparency and individual rights implications.
• Establishing appropriate human oversight and escalation.
• Evaluating vendor, security, and operational risks.
• Monitoring applicable legislation, regulatory guidance, and policy developments.

Relevant considerations may include:

• Financial services and financial consumer protection.
• Telecommunications and digital communications.
• Healthcare and sensitive personal information.
• Employment and human resources data.
• Public-sector contracts and government-related services.
• International privacy laws where their territorial scope applies.