The Superintendency of Industry and Commerce, through the Single Circular, in numeral 2.3 of Chapter II of Title V, determined that those responsible for the Processing of Personal Data must annually update the information registered in the National Database Registry (NDBR)[1], between January 2 and March 31, starting in 2020.
However, due to the health emergency caused by COVID-19 declared by Resolution No. 385 of March 12, 2020 of the Ministry of Health and Social Protection, and, in accordance with the provisions of Decree No. 457 of March 22, 2020, by virtue of which the mandatory preventive isolation of the inhabitants of the Colombian territory was ordered from March 25, 2020, until April 13, 2020, the Superintendency of Industry and Commerce issued External Circular No. 003 of March 30, 2020, through which it extended the deadline for carrying out the update of the information contained in the National Database Registry until July 3, 2020.
The aforementioned Circular was issued with the aim of mitigating and preventing the spread of COVID-19, since obtaining the data to proceed with the update of the information registered in the National Database Registry sometimes implies the movement of people to the different offices or facilities of their companies, a situation that facilitates the spread and propagation of COVID-19.
Finally, it is reiterated that the maximum
deadline to carry out the respective update of the information contained in
the National Database Registry has been extended from March 31 to
July 3, 2020, in accordance with the External Circular recently issued
by the Superintendency of Industry and Commerce.
[1] Article 25 of Law 1581 of 2012 defines the National Database Registry as “[t]he public directory of databases subject to Processing that operate in the country”, and determines that it “will be administered by the Superintendency of Industry and Commerce and will be freely consultable by citizens.”.
Author: Manuela Rodriguez A. AZC Consulting Attorney