Meet Hungary's Info Act and GDPR duties from one set of controls
The Info Act is Hungary's Act CXII of 2011 on the Right of Informational Self-Determination and on Freedom of Information, the country's main data protection law alongside the GDPR.
- Full title
- Act CXII of 2011 on the Right of Informational Self-Determination and on Freedom of Information
- Passed by
- Hungarian Parliament
- In force since
- 1 January 2012
- GDPR alignment
- Amended by Act XXXVIII of 2018, in force 26 July 2018
Is the Info Act right for your organisation?
Amended by Act XXXVIII of 2018 to align with the GDPR, it adds Hungarian specific rules, governs processing outside the GDPR's scope, and establishes the NAIH as the supervisory authority.
Any organisation processing personal data in Hungary must follow the GDPR together with the Info Act's supplementary rules, including NAIH procedures, court remedies and rights after a data subject's death. Public bodies also face the Act's freedom of information duties, and law enforcement, national security and defence bodies are governed by its full data protection regime.
How OneClickComply helps with the Info Act
OneClickComply supports the Info Act today, so Hungarian requirements can sit on top of the GDPR controls you already run. Evidence collected once, from records of processing to breach handling and DPO arrangements, counts towards both, and continuous monitoring flags when those controls drift.
Requirements covered
89 numbered sections, plus many lettered insertions, across 11 chapters, with data protection requirements in Chapters II, II/A and II/B and NAIH powers and procedures in Chapters V and VI.
Manual Info Act compliance vs OneClickComply
Doing it manually
- Working out which Info Act sections apply on top of the GDPR and which do not
- Reading Hungarian consolidated text or unofficial translations to track amendments
- Keeping records of processing and processor contracts up to date by hand
- Gathering breach, DPO and security evidence from scattered tools before an NAIH inquiry
- Maintaining separate spreadsheets for GDPR and Hungarian national requirements
With OneClickComply
- Hungarian requirements mapped to controls, so you see exactly what applies
- Expert guidance from the in-house audit team when the law changes
- Processing records and vendor data refreshed through integrations
- Evidence collected continuously and ready if the NAIH asks
- One control set covering both the GDPR and the Info Act
Everything you need for the Info Act
Info Act requirements mapped onto your existing GDPR control set
Records of processing activities kept current from connected systems
Breach handling workflow with evidence of assessment and NAIH notification
AutoComplete privacy and data security policies built from your environment
Vendor risk management for processors and onward transfers
Ask an Auditor guidance on Hungarian specific obligations
Three steps to Info Act compliance
Connect and scan
Connect your cloud, identity and SaaS tools. OneClickComply checks them against the Info Act and shows which controls pass and which fail.
Fix and generate
OneClickFix fixes supported misconfigurations automatically, and AutoComplete drafts Info Act policies from your real environment.
Monitor and evidence
Continuous monitoring flags drift as it happens, and our in-house audit team is on hand when you need expert guidance.
See how far your current setup is from the Info Act.
Hungarian Information Act (Act CXII of 2011) requirements
The Act's sections grouped by their official subheadings and chapters, with English titles translated from the current consolidated Hungarian text.
| Reference | Requirement |
|---|---|
| Section 1 | Object of the Act |
| Section 2 | Scope of the Act and relationship with the GDPR |
| Section 3 | Definitions |
| Section 4 | Principles of processing personal data |
| Sections 5-7 | Legal basis and general conditions of processing |
| Sections 8-13 | Conditions of data transfers, including international transfers |
| Section 14 | Rights of the data subject |
| Sections 15-22 | Ensuring the exercise of data subject rights |
| Section 23 | Court action against the controller or processor |
| Section 24 | Liability for damage and compensation for infringement of personality rights |
| Section 25 | Exercise of data protection rights after the data subject's death |
| Sections 25/A-25/B | General obligations of the controller |
| Sections 25/C-25/D | The processor |
| Sections 25/E-25/F | Records of processing activities and electronic logs |
| Sections 25/G-25/H | Data protection impact assessment and prior consultation |
| Section 25/I | Data security measures |
| Sections 25/J-25/K | Handling personal data breaches |
| Sections 25/L-25/N | Data protection officer |
| Sections 26-31/C | Access to data of public interest |
| Sections 32-37/C | Publication of data of public interest |
Always check the official text of the Info Act for the exact wording.
Info Act questions, answered
Can't find what you need? Our in-house auditors can talk you through the Info Act on a 30-minute call.
What is the Hungarian Info Act?
The Info Act is Hungary's Act CXII of 2011 on the Right of Informational Self-Determination and on Freedom of Information. It is the national data protection and freedom of information law, in force since 1 January 2012. Since its 2018 amendment it supplements the GDPR for most processing, sets up the NAIH and its procedures, and fully regulates processing for law enforcement, national security and defence purposes.
Does the GDPR or the Info Act apply in Hungary?
Both apply. The GDPR applies directly to most processing of personal data, and the Info Act adds Hungarian supplementary rules, such as NAIH procedures, court remedies and the exercise of rights after a data subject's death. For law enforcement, national security and defence processing, which falls outside the GDPR, the Info Act's own data protection chapters apply in full.
Who must comply with the Info Act?
Every controller and processor handling personal data in Hungary must comply, whether a private company or a public body. Businesses mainly meet the GDPR plus the Act's supplementary provisions. Public bodies also have freedom of information duties to disclose and publish data of public interest, and law enforcement, national security and defence bodies follow the Act's full data protection regime.
Who enforces the Info Act and what are the penalties?
The National Authority for Data Protection and Freedom of Information (NAIH) enforces it, through investigations and data protection authority proceedings. For processing within the GDPR's scope, fines follow GDPR Article 83. For processing under the Act's own regime, the NAIH can impose fines from HUF 100,000 to HUF 20 million. Individuals can also sue controllers and processors for damages in court.
Does Hungary require a data protection officer?
Yes, where the GDPR requires one, and under the Info Act's own regime a controller or processor must appoint a data protection officer if it performs state or other public tasks, other than the courts, or if a law requires it. Controllers must notify the NAIH of the officer's contact details and publish them.
How does the Info Act relate to ISO 27001?
The Info Act is a legal obligation, while ISO 27001 is a voluntary certifiable standard for information security management. ISO 27001 controls help meet the Act's and the GDPR's data security, breach handling and access requirements, but certification does not prove legal compliance. Many organisations use ISO 27001 as the security backbone of their Hungarian privacy programme.
How do I comply with the Info Act?
Start with GDPR compliance, then add the Hungarian specifics. Map your processing activities, confirm lawful bases, keep records of processing, run impact assessments where needed, handle breaches and notify the NAIH, and appoint a data protection officer where required. Check the Hungarian consolidated text for current wording, as the Act is amended regularly.
Does OneClickComply support the Hungarian Info Act?
Yes. OneClickComply supports the Hungarian Info Act today. Because it builds on controls shared with the GDPR, evidence you already collect for GDPR can count towards it. OneClickComply does not issue certifications or guarantee legal compliance, and Ask an Auditor can help with Hungarian questions.
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