# Specific processing situations

Source: https://conformitate.md/en/law-195-2024/specific-processing-situations
Updated: 2026-10-15

Law 195/2024

Law No. 195/2024 has special rules for four situations: processing for journalistic, academic, artistic or literary purposes (art. 51), access to information of public interest (art. 52), processing of the national identification number (art. 53), and processing for archiving, scientific or historical research or statistical purposes (art. 54).

## Freedom of expression

For processing for journalistic purposes or for academic, artistic or literary expression, the Law does not apply if three conditions are met together: the controller processes the data with the intention of publishing material, publication would be in the public interest, and applying the Law would be incompatible with those purposes [art. 51(1)](https://conformitate.md/en/law-195-2024/article-51#p1 "Processing and freedom of expression").

The National Centre for Personal Data Protection does not supervise these operations [art. 51(2)](https://conformitate.md/en/law-195-2024/article-51#p2 "Processing and freedom of expression"). A data subject who considers that the conditions have not been met may bring an action before a court and claim compensation [art. 51(3)](https://conformitate.md/en/law-195-2024/article-51#p3 "Processing and freedom of expression"). The exception does not cover access to information of public interest, which has its own rule [art. 51(4)](https://conformitate.md/en/law-195-2024/article-51#p4 "Processing and freedom of expression").

## Access to information of public interest

Personal data held by controllers may be disclosed under the conditions of Law No. 148/2023 on Access to Information of Public Interest, except for special categories of data [art. 52(1)](https://conformitate.md/en/law-195-2024/article-52#p1 "Processing and access to information of public interest"). This rule does not concern a person’s request for access to his or her own data; such a request follows the rules on data subject rights [art. 52(2)](https://conformitate.md/en/law-195-2024/article-52#p2 "Processing and access to information of public interest").

## The national identification number

The national identification number is the number by which a natural person is identified in certain filing systems and which is of general application, such as the state identification number or the series and number of the identity card [art. 4](https://conformitate.md/en/law-195-2024/article-4#term-17 "national identification number").

It may be processed, including by collecting or disclosing documents that contain it, in any of the situations of lawful processing in [art. 6(1)](https://conformitate.md/en/law-195-2024/article-6#p1 "Lawfulness of processing"), [art. 53(1)](https://conformitate.md/en/law-195-2024/article-53#p1 "Processing of a national identification number"). Where the basis is the legitimate interest of the controller or of a third party, the controller must put specific safeguards in place [art. 53(2)](https://conformitate.md/en/law-195-2024/article-53#p2 "Processing of a national identification number"):

-   appropriate technical and organisational measures for data minimisation and for the security of processing [art. 53(2)(a)](https://conformitate.md/en/law-195-2024/article-53#p2-a "Processing of a national identification number");
-   storage periods set according to the nature of the data and the purpose, and time limits for erasure or review [art. 53(2)(b)](https://conformitate.md/en/law-195-2024/article-53#p2-b "Processing of a national identification number");
-   regular training for the people who process the data under the direct authority of the controller or processor [art. 53(2)(c)](https://conformitate.md/en/law-195-2024/article-53#p2-c "Processing of a national identification number").

For example, copying the identity cards of clients or visitors means collecting documents that contain the national identification number, so it needs a basis under art. 6(1) [art. 53(1)](https://conformitate.md/en/law-195-2024/article-53#p1 "Processing of a national identification number").

## Archiving, research and statistics

Processing for archiving purposes in the public interest, for scientific or historical research purposes or for statistical purposes takes place only subject to appropriate safeguards for the rights and freedoms of data subjects. The safeguards ensure in particular data minimisation and may include pseudonymisation; where the purposes can be achieved without identifying individuals, they are achieved in that way [art. 54(1)](https://conformitate.md/en/law-195-2024/article-54#p1 "Processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes").

In scientific or historical research and in statistics, subject to the safeguards in paragraph (1), the rights of access, to rectification, to restriction and to object do not apply to the extent that they would render impossible or seriously impair the achievement of the purposes, and the derogation is necessary [art. 54(2)](https://conformitate.md/en/law-195-2024/article-54#p2 "Processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes"). For archiving in the public interest, the derogation also extends to notifying recipients and to data portability [art. 54(3)](https://conformitate.md/en/law-195-2024/article-54#p3 "Processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes"). The derogations apply only to processing for those purposes, not to other purposes pursued at the same time [art. 54(4)](https://conformitate.md/en/law-195-2024/article-54#p4 "Processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes").

## Why it matters

Infringements of the obligations in this Chapter are punishable by fines of up to 2,000,000 lei or, for an enterprise, of up to 2% of total turnover, whichever is higher [art. 88(2)(d)](https://conformitate.md/en/law-195-2024/article-88#p2-d "Infringements punishable by a fine").

## How we can help with this

-   [GDPR Moldova compliance assessment →](https://conformitate.md/en/services/compliance-assessment)
    
    We assess online how your company processes personal data and give you a written report of what is missing under Law No. 195/2024, in order of priority.
    

## Articles in this topic

1.  [Article 51 Processing and freedom of expression](https://conformitate.md/en/law-195-2024/article-51)
2.  [Article 52 Processing and access to information of public interest](https://conformitate.md/en/law-195-2024/article-52)
3.  [Article 53 Processing of a national identification number](https://conformitate.md/en/law-195-2024/article-53)
4.  [Article 54 Processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes](https://conformitate.md/en/law-195-2024/article-54)

**The Romanian and Russian texts are those published in Monitorul Oficial. This English text is an unofficial translation by conformitate.md and has no legal force.**

Not an official publication. The Law was published in Monitorul Oficial No. 367-369/2024, art. 574.

Text verified on 15 October 2026 · [Romanian text on legis.md](https://www.legis.md/cautare/getResults?doc_id=144681&lang=ro)

FAQ

## What clients ask us

### Can a company collect its clients’ state identification number?

The national identification number may be processed in the situations of lawful processing set out in art. 6(1). Where the basis is the legitimate interest of the controller or of a third party, the Law also requires specific safeguards: data minimisation and security measures, set storage periods, and regular training for the people who process the data. [art. 53](https://conformitate.md/en/law-195-2024/article-53 "Processing of a national identification number") [art. 6](https://conformitate.md/en/law-195-2024/article-6 "Lawfulness of processing")

### Does the Law apply to journalists?

The Law does not apply to processing for journalistic purposes if three conditions are met together: the intention to publish the material, the public interest in publication, and the incompatibility of applying the Law with the journalistic purpose. The data subject may nevertheless go to court and claim compensation. [art. 51](https://conformitate.md/en/law-195-2024/article-51 "Processing and freedom of expression")

### Can personal data be disclosed in response to a request for public interest information?

Yes, under the conditions of Law No. 148/2023 on Access to Information of Public Interest, except for special categories of data. A person’s request for access to his or her own data, however, is handled under the rules on data subject rights. [art. 52](https://conformitate.md/en/law-195-2024/article-52 "Processing and access to information of public interest")

### Do data subject rights apply to scientific research?

The rights of access, to rectification, to restriction and to object do not apply to the extent that they would render impossible or seriously impair the achievement of the research purposes, provided that appropriate safeguards exist and the derogation is necessary. [art. 54](https://conformitate.md/en/law-195-2024/article-54 "Processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes")

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