The Unified Circular of the Superintendence of Industry and Commerce (the “Superintendence“), states in its numeral 2.3. of Chapter Two of Title Five that, it is the obligation of those responsible for the processing of personal data to update the information registered in the National Registry of Databases (“RNBD” by its Spanish acronym) annually, between January 2 and March 31, starting in 2020. However, on the occasion of the COVID-19 pandemic, the mandatory preventive isolation measures decreed by the National Government and the objective of avoiding the displacement of people to the headquarters of their companies or entities, the Superintendence extended the deadline for updating the information registered in the RNBD until July 3, 2020, by means of External Circular No. 003 of March 30, 2020.
Please note that the following are obliged to carry out the registration before the RNBD: (i) companies and non-profit entities that have total assets exceeding 100,000 Tax Value Units (“TVU“) and (ii) legal entities of a public nature, in accordance with the provisions of Decree 090 of 2018. For better understanding, please refer to the following table:
Required to register their databases before de RNBD:
Type of legal entity Asset value
Companies and Non-Profit Entities Total assets over 610.000 UVT ($21,720,270,000)
Companies and Non-Profit Entities Total assets over 100.000 UVT ($3,560,700,000)
Legal entities of a public nature Not applicable
Not required to register their databases with the RNBD
Companies and Non-Profit Entities Total assets of 100.000 UVT ($3,560,700,000) o menos
Natural persons Not applicable
*UVT 2020: $35,607
The above information is offered as an information service to our clients and does not constitute legal advice.