<![CDATA[The digitalization of notarial services has encouraged prospective appearers to exchange documents through instant messaging applications and electronic mail before an authentic deed is executed. Such practices facilitate preliminary verification but expose identity, taxation, financial, and ownership documents to data-breach risks when stored on inadequately secured devices or electronic platforms. This study examines the legal status of personal-data processing during the pre-deed stage and formulates the legal responsibility of notaries when a breach occurs. It employs normative legal research using statutory, conceptual, and analytical approaches. The study finds that a notary's duty of confidentiality under the Notary Office Law arises when information is obtained for the purpose of preparing a deed and is not contingent upon the deed having been executed. A notary who determines the purposes and means of processing may also qualify as a Personal Data Controller under the Personal Data Protection Law. A pre-deed data breach may trigger professional-administrative, personal-data administrative, civil, and, under specific circumstances, criminal liability. Appropriate safeguards should include purpose limitation, data minimization, access controls, separation of devices, retention policies, secure deletion, processing records, and documented incident-response procedures.]]>
Copyrights © 2026
