Abstract
In line with the expansion of Humanitarian Non-governmental organizations activities and its scope in Iraq, its daily contact with the individuals is getting increased, and a critical aspect of this contact is related to processing of personal data of those individuals. In absence of data protection law in Iraq, this data processing has been subject to plenty of question marks in terms of its usage and proportionality with the purposes that the data has been collected for, then the penalties that will be applied to the people who violate the privacy of such data, especially the sensitive data. Any violation of this privacy will result in negative consequences and damage for victims either in their person, property, reputation, or families. One of the questions that is being repeated is the criminal liability of humanitarian organizations about the crimes that are being committed by their employees in violation of personal data privacy.
The legislative gap in Iraq for having a special law for the protection of personal data, the criminal protection of such data and the criminal liability of NGOs seems incomplete, which requires the intervention of the legislator to determine the borders of this criminal protection and the criminal liability of NGOs, particularly taking in consideration that such NGOs are in direct contact with vulnerable people that could be subject to crimes more than others.
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