Cases of processing personal data without the consent of the subject

Legal Consulting Office of Lao Dong Newspaper answers:

Clause 1, Article 19 of the 2025 Law on Personal Data Protection (effective from January 1, 2026) stipulates cases of processing personal data without the consent of the personal data subject including:

a) To protect the life, health, honor, dignity, legitimate rights and interests of the subject of personal data or others in urgent cases; protect the legitimate rights or interests of themselves, others, or the interests of the State, agencies, and organizations in a necessary way before the above-mentioned act of infringing upon interests. The controller of personal data, the controller of personal data, the controller and controller of personal data, and the third party are responsible for proving this case;

b) To resolve the state of emergency; the risk of threatening national security but not to the extent of declaring the state of emergency; preventing and combating riots, terrorism, crime prevention and law violations;

c) Serving the operation of state agencies and state management activities in accordance with the law;

d) Implementing agreements of personal data subjects with relevant agencies, organizations, and individuals in accordance with the law;

e) Other cases as prescribed by law.

Thus, from January 1, 2026, the above cases will handle personal data without the consent of the personal data subject.