In accordance with the principle of transparency, the Ministry of Justice, as the controller, is obliged to inform the data subject about the processing of personal data concerning that data subject. The information obligation under Article 13 of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter also “GDPR”), applies to the controller in the event that personal data were obtained directly from the data subject, i.e., the data subject provided or communicated their personal data directly to this controller.
The Ministry of Justice provides information on the processing of personal data of persons in the Insolvency Register information system (hereinafter also “eISIR”) and in the List of Insolvency Practitioners (hereinafter also “SEZIS”).
- The Insolvency Register is a public administration information system managed by the Ministry of Justice. The Insolvency Register contains a list of insolvency practitioners, a list of debtors, and insolvency files. The Insolvency Register is publicly accessible, with the exception of data as determined by the Insolvency Act. Everyone has the right to inspect the insolvency register and make copies and extracts from it. Upon request, the Ministry of Justice or the insolvency court issues an officially certified output from the insolvency register. The legal basis is primarily contained in Section 419 et seq. of Act No. 182/2006 Coll., on Insolvency and Methods of its Resolution (Insolvency Act).
- The List of Insolvency Practitioners represents a part of the insolvency register, which is a public administration information system managed by the Ministry of Justice. The SEZIS system is primarily used to administer and publish data on insolvency practitioners. The legal basis is primarily contained in Section 16 et seq. of Act No. 312/2006 Coll., on Insolvency Practitioners.
The legal basis for the processing of personal data in the Insolvency Register and the List of Insolvency Practitioners is Article 6(1)(c) of the GDPR – processing is necessary for compliance with a legal obligation to which the controller is subject; in this case, the obligations to manage the aforementioned information systems arise from generally binding legal regulations.
This information on the processing of personal data may be further updated and adjusted in the future based on legislative or operational needs.
The current version of the information on personal data processing can always be found on this website.
Insolvency Register – information pursuant to Article 13 of the GDPR
| Controller Information | Ministry of Justice Address: Vyšehradská 16, 128 12 Prague 2 – Nové Město Company ID (IČO): 00025429 Data Box ID: kq4aawz E-mail: posta@msp.justice.cz |
| Data Protection Officer | Mgr. Jan Panoš Address: Vyšehradská 16, 128 12 Prague 2 – Nové Město E-mail: poverenec@msp.justice.cz |
| Sources of Personal Data | The data subject; Subjects participating in insolvency proceedings under Act No. 182/2006 Coll., on Insolvency and Methods of its Resolution (Insolvency Act); Public administration information systems, basic registries and agenda information systems used by the insolvency court for the purpose of conducting insolvency proceedings. |
| Purpose of Processing | The legal basis for processing personal data under the GDPR is the fulfillment of a legal obligation imposed on the Ministry and courts during the management of the public administration information system, or the maintenance of the Insolvency Register, by the following legal regulations: Act No. 182/2006 Coll. (Insolvency Act); Act No. 312/2006 Coll. (Insolvency Practitioners); Act No. 6/2002 Coll. (Act on Courts and Judges); Act No. 111/2009 Coll. (Basic Registries); Act No. 365/2000 Coll. (Public Administration Information Systems). |
| Categories of Data Subjects | Procedural subjects of insolvency proceedings; Subjects mentioned in documents delivered to the insolvency court and published in the Insolvency Register; Subjects registered in the List of Insolvency Practitioners. |
| Categories of Processed Data | Identification data: first name, surname, date of birth, birth number (to the extent required by law), name, Company ID (IČO), residential address, registered office, residence if different from the residential address. Contact details: e-mail, phone, Data Box ID. Technical and audit data: IP address, access time, device identifier, type of operation. Other information about persons defined by law, in particular: – data contained in documents published in the Insolvency Register according to Section 420 et seq. of the Insolvency Act; – data recorded in the List of Insolvency Practitioners according to Section 18 et seq. of Act No. 312/2006 Coll., on Insolvency Practitioners. |
| Categories of Personal Data Recipients | A natural or legal person, public authority, or another entity that inspects the public part of the Insolvency Register or inspects the non-public part of the insolvency file via remote access. (Public authorities that may receive personal data in the framework of a particular inquiry in accordance with legal regulations are not considered recipients under the GDPR). Personal data processor – IBM Česká republika, spol. s.r.o., as the information system provider, and Aricoma Digital s.r.o. as the information system sub-processor – in the event of necessary system adjustments and maintenance, within the strictly necessary and controlled scope of inspection. Exceptions to the public availability of data are stipulated by the relevant legal regulation (e.g., Section 7b, Section 100a, Section 126, Section 422 and 423 of the Insolvency Act). |
| Transfer of Personal Data Abroad | In accordance with Article 25 of Regulation (EU) 2015/848 of the European Parliament and of the Council of 20 May 2015 on insolvency proceedings, selected publicly available data on insolvency proceedings, including data on debtors, are made available via a decentralized information system to the European portal managing the interconnection of national insolvency registers. |
| Period for which Personal Data may be Published | The period for recording data about the debtor in the list of debtors and the debtor’s insolvency file in the Insolvency Register is regulated in Section 425 of the Insolvency Act as follows: (1) After 5 years from the date on which the decision ending the insolvency proceedings becomes final and binding, the insolvency court shall strike the debtor from the list of debtors and restrict access to the data about them in the Insolvency Register. (2) If the method of resolving insolvency is debt relief and the debtor is discharged under Section 414, the insolvency court shall strike the debtor from the list of debtors and restrict access after 3 years from the final discharge decision. (3) Archiving follows Act No. 499/2004 Coll. (Act on Archiving and Records Management). (4) During appeals, data remains accessible in the Insolvency Register. Practitioner data is linked to their duration of authorization under Act No. 312/2006 Coll. |
| Automated Decision-Making/Profiling System Security | Processing is not based on automated processing or profiling (Art. 22 GDPR). The system meets all security conditions under Act No. 264/2025 Coll., on Cybersecurity, and internal Ministry of Justice regulations. |
| Rights of Data Subjects | The entry and maintenance of data in the Insolvency Register falls within the decision-making powers of the courts and the competence of the Ministry of Justice. In this area, the data subject may exercise the following rights: Right of access (Art. 15 GDPR) Right to rectification (Art. 16 GDPR) Right to erasure (Art. 17 GDPR) Right to data portability (Art. 20 GDPR) Right to lodge a complaint (Art. 77 GDPR) Right to object (Art. 21(1) GDPR) These rights can be exercised at the relevant court or the Ministry of Justice. |
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