Cases of personal data processing that do not require the subject's consent

The Lao Dong Newspaper Legal Consulting Office replied:

Clause 1, Article 19 of the Law on Personal Data Protection 2025 (effective from January 1, 2026) stipulates cases where personal data processing does not require the consent of personal data subjects, including:

a) To protect the life, health, honor, dignity, rights and legitimate interests of personal data subjects or others in urgent cases; to protect the legitimate rights or interests of oneself, others or the interests of the State, agencies and organizations as necessary against the above-mentioned infringement of interests. The personal data controller, the personal data processing party, the personal data controller and processing party, and the third party are responsible for proving this case;

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

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

d) Implement the agreement of the personal data subject with relevant agencies, organizations and individuals according to the provisions of law;

d) Other cases as prescribed by law.

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

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