# Data protection for homeowners associations Source: https://conformitate.md/en/industries/homeowners-associations Updated: 2026-10-15 Homeowners associations A homeowners association is the controller of its residents’ data: names, flats, meter readings, debts and CCTV footage. Each processing operation needs a legal basis (art. 6), and residents must be informed (art. 13). Posting debts and CCTV are limited to the data the purpose requires. The chair and the building manager process data only on the association’s instructions. ![An apartment block entrance with mailboxes and a camera that films only the entrance](/_astro/asociatii-de-proprietari-1200.CD8OKIq-.webp) ## Industry-specific risks ### Debts posted at the entrance A list with the names and flat numbers of residents in arrears, posted in the stairwell, discloses data to everyone who passes by. Even a flat number without a name can identify the owner. [art. 4](https://conformitate.md/en/law-195-2024/article-4 "Definitions") [art. 5](https://conformitate.md/en/law-195-2024/article-5 "Principles relating to processing") [art. 6](https://conformitate.md/en/law-195-2024/article-6 "Lawfulness of processing") ### CCTV in common areas Monitoring stairwells and the courtyard requires a legal basis, informing the people filmed, and keeping the footage only for as long as necessary. [art. 5](https://conformitate.md/en/law-195-2024/article-5 "Principles relating to processing") [art. 6](https://conformitate.md/en/law-195-2024/article-6 "Lawfulness of processing") [art. 13](https://conformitate.md/en/law-195-2024/article-13 "Information to be provided where personal data are collected from the data subject") ### Data in group chats Residents’ data shared in Viber or Telegram groups can reach unauthorised persons and escapes the association’s control. [art. 5](https://conformitate.md/en/law-195-2024/article-5 "Principles relating to processing") [art. 25](https://conformitate.md/en/law-195-2024/article-25 "Data protection by design and by default") [art. 32](https://conformitate.md/en/law-195-2024/article-32 "Security of processing") ## Data you process First and last name Address and flat number IDNP for contracts Phone and email Meter readings Debts and payments CCTV footage ## Your obligations under Law No. 195/2024 1. A legal basis for each processing operation, including CCTV [art. 6](https://conformitate.md/en/law-195-2024/article-6 "Lawfulness of processing") 2. Informing residents about the processing of their data [art. 13](https://conformitate.md/en/law-195-2024/article-13 "Information to be provided where personal data are collected from the data subject") 3. Only the data the purpose requires, kept only for as long as necessary [art. 5](https://conformitate.md/en/law-195-2024/article-5 "Principles relating to processing") 4. Records of processing activities, where the processing is not occasional [art. 30](https://conformitate.md/en/law-195-2024/article-30 "Records of processing activities") 5. Written contracts with an external building manager and with providers that process data on the association’s behalf [art. 28](https://conformitate.md/en/law-195-2024/article-28 "Processor") 6. Instructions for the people who have access to residents’ data [art. 29](https://conformitate.md/en/law-195-2024/article-29 "Carrying out processing activities under the authority of the controller or the processor") [art. 32](https://conformitate.md/en/law-195-2024/article-32 "Security of processing") ## Documents we deliver Every document is tailored to your activity, not copied from a template. Records of processing activities [art. 30](https://conformitate.md/en/law-195-2024/article-30 "Records of processing activities") Privacy notice for residents [art. 13](https://conformitate.md/en/law-195-2024/article-13 "Information to be provided where personal data are collected from the data subject") CCTV policy [art. 5](https://conformitate.md/en/law-195-2024/article-5 "Principles relating to processing") [art. 24](https://conformitate.md/en/law-195-2024/article-24 "Responsibility of the controller") CCTV information sign [art. 12](https://conformitate.md/en/law-195-2024/article-12 "Transparency of information, communications and modalities for the exercise of the rights of the data subject") [art. 13](https://conformitate.md/en/law-195-2024/article-13 "Information to be provided where personal data are collected from the data subject") Contracts with processors [art. 28](https://conformitate.md/en/law-195-2024/article-28 "Processor") How we work ## From the first conversation to a complete compliance file 1. 1 ### Free consultation 15 minutes online or by phone. We learn what your company does and what personal data it processes. 2. 2 ### Assessment We take stock of your data, processes and existing documents. You receive a gap report. 3. 3 ### Documentation We draft the records, policies and privacy notices tailored to your activity. 4. 4 ### Implementation We walk you through the documents and leave a written note for employees; on request, we hold a briefing session for them. For a typical homeowners association The Essential package + extra work, 12,400 MDL This is an estimate for a typical organisation in the industry, with up to 20 people working with the data. The exact price depends on what you do with the data. [Calculate the exact price →](https://conformitate.md/en/tools/price-calculator?profil=asociatii-de-proprietari) Packages ## Fixed prices, no surprises Choose a package by how your company processes data, not by headcount. Prices start from the lawyer's work, and a package costs less than its modules bought separately. ### Essential 5,900 MDL Module value: 18,500 MDL · you save 12,600 MDL Up to 3 processing activities · 2 privacy notices · 2 processor contracts For a small company with simple processing: a shop, an office, an accounting firm, a homeowners' association. - Data inventory and gap report - Records of processing activities, with the legal basis and retention period of each - Data protection policy and a description of the security measures - Privacy notices for each group of people: clients, employees, patients - Contracts with processors, new or reviewed - Internal rules for data subject requests and for personal data breaches - The confidentiality commitment and the written note for employees Online · delivered in 10 working days · 1 round of revisions · 14 calendar days of email questions [Choose Essential →](https://conformitate.md/en/industries/homeowners-associations?pkg=essential#oferta) ### Extended Most popular 19,900 MDL Module value: 44,000 MDL · you save 24,100 MDL Up to 8 activities · 5 notices · 5 contracts · website, cameras, sensitive data For a small or medium company with varied processing: a clinic, an online shop, surveillance cameras, cloud services abroad. - Everything in Essential, with higher limits - Website privacy policy and cookie review - Video surveillance: notice, sign text, internal rules - Sensitive data in one activity (for example, medical records) - Transfers outside Moldova, one group of destinations - We check whether you need an impact assessment and a data protection officer Online · delivered in 20–30 working days · 2 rounds of revisions · 45 calendar days of email questions [Choose Extended →](https://conformitate.md/en/industries/homeowners-associations?pkg=extended#oferta) ### Custom from 45,000 MDL No limits · analysis at your premises For clinic networks, banks and microfinance companies, groups of companies, public bodies, or companies that must appoint a data protection officer. - Everything in Extended, with no limits - Data protection impact assessments, as many as needed - Review of data flows and IT systems - Joint controller agreements, profiling, complex transfers Priced after analysis, at module prices [Request a quote →](https://conformitate.md/en/industries/homeowners-associations?pkg=custom#oferta) Not sure which package fits? [Calculate the price →](https://conformitate.md/en/tools/price-calculator) [Request a free 15-minute consultation →](https://conformitate.md/en/industries/homeowners-associations?pkg=consult#oferta) Documents are drafted in Romanian; an authorised translation into Russian or English is charged separately, at the translator's rate. ## Case studies and checklist [ Case study Illustrative example ### Case study: homeowners association A homeowners association in Chișinău with 120 flats. The cameras in the stairwells and the courtyard ran with no rules of use, no notice to residents and no retention period for the recordings, and the list of debtors was posted at the entrance with names and flat numbers. The firm that maintained the cameras had access to the recordings, and exported clips were posted to the building's group chat on request. Result The association now has a CCTV policy, warning signs, a privacy notice for residents, a retention period for the recordings, a contract with the maintenance firm and a format for the list of debts that does not identify anyone. ](https://conformitate.md/en/case-studies/homeowners-association) FAQ ## What clients ask us ### Can we post the list of debtors in the stairwell? The Law has no specific rule on lists of debts. Posting one is processing that needs a legal basis and is limited to the data the purpose requires. Even a flat number without a name can identify the owner, so it is still personal data. [art. 4](https://conformitate.md/en/law-195-2024/article-4 "Definitions") [art. 5](https://conformitate.md/en/law-195-2024/article-5 "Principles relating to processing") [art. 6](https://conformitate.md/en/law-195-2024/article-6 "Lawfulness of processing") ### Do we need residents’ consent for CCTV? Not necessarily. Consent is only one of the legal bases listed in art. 6(1); the association may rely, for example, on legitimate interests, unless another law provides otherwise or the residents’ rights override them. Whatever the legal basis, the people filmed must be informed, and footage is kept only for as long as necessary. [art. 5](https://conformitate.md/en/law-195-2024/article-5 "Principles relating to processing") [art. 6](https://conformitate.md/en/law-195-2024/article-6 "Lawfulness of processing") [art. 13](https://conformitate.md/en/law-195-2024/article-13 "Information to be provided where personal data are collected from the data subject") ### Who is responsible for the data: the chair or the association? The association, as the controller that determines the purposes and means of the processing. The chair and the board members act under its authority and process data only on its instructions. An external building manager that processes data on the association’s behalf is a processor and needs a written contract. [art. 4](https://conformitate.md/en/law-195-2024/article-4 "Definitions") [art. 28](https://conformitate.md/en/law-195-2024/article-28 "Processor") [art. 29](https://conformitate.md/en/law-195-2024/article-29 "Carrying out processing activities under the authority of the controller or the processor") --- Provider: conformitate.md · RIGHT CONSULT COMPANY (IDNO 1022600002005) · MD-2072, mun. Chișinău, sect. Botanica, str. Grenoble 259/6, of. 57 Phone: +373 767 27 667 · Email: contact@conformitate.md Prices: https://conformitate.md/en/pricing