Data protection for private individuals in Switzerland

Art. 24 DPO

Exemption from the obligation to keep a record of processing activities

Chapter 4: Special Provisions on Data Processing by Private Persons

Statutory textStatus: 1 December 2025

Undertakings and other private organisations employing fewer than 250 employees on 1 January of any year and natural persons are exempt from the obligation to keep a record of processing activities unless any one of the following requirements is met:

  • a.

    a large volume of sensitive personal data is being processed;

  • b.

    high-risk profiling is being carried out.

Source: Version on FedlexThis translation is not an official version. Only the German, French and Italian versions are legally binding.

In brief

Companies and other private-law organisations with fewer than 250 employees on 1 January of a year, as well as natural persons, do not have to keep a record of processing activities (Art. 12 FADP). This does not apply if they process a large volume of sensitive personal data or carry out high-risk profiling.

What does this mean for me?

This rule is aimed at companies and others who process data. For you, it means: even if a smaller company does not have to keep a record, your right of access against it remains (Art. 25 FADP).

Implements these provisions of the Federal Act on Data Protection (FADP)

  1. Art. 12 FADPRecord of processing activities

Explanation by mydatenschutz.ch in plain language – not legal advice. The statutory text is authoritative.