Serbia Law 87/2018 compliance gap analysis: where GDPR-based pipelines break for Serbian data protection
Geert WarmenbolApril 29, 2026
Key takeaways
Serbia's Law on Personal Data Protection (ZZPL, Official Gazette 87/2018) is modeled on GDPR but is not identical to it. Organizations running GDPR-compliant programs do not automatically satisfy ZZPL requirements -- the gap is operational, not structural.
The European Commission granted Serbia an adequacy decision in 2024. This changes the cross-border transfer picture for EU-to-Serbia and Serbia-to-EU data flows, but it introduces new compliance steps: organizations that documented Serbian transfers as requiring SCCs or consent now need to update their transfer records, and organizations that restricted transfers to Serbia need to revise that position.
Serbia's Poverenik (Commissioner for Information of Public Importance and Personal Data Protection) has a breach notification format and timeline requirement that differs from GDPR Article 33. Automated breach notification workflows built for GDPR produce outputs that do not satisfy Poverenik notification requirements without Serbian-specific configuration.
DPIA thresholds under ZZPL Article 54 include criteria that do not map directly to GDPR Article 35. Specifically, the Poverenik publishes a list of processing activities requiring DPIAs under Serbian law -- this list is not identical to the lists published by EU supervisory authorities. Organizations using EU DPA DPIA trigger lists for Serbian operations will miss processing activities on the Poverenik's list.
In Vulnox assessments, DPIA process gaps were the most consistent finding in Serbian entities -- including organizations running GDPR-certified compliance platforms. The gap was not absence of a DPIA process but absence of a DPIA process calibrated to the Poverenik's trigger list.
TL;DR
Serbia's data protection law is close enough to GDPR that organizations assume coverage transfers. It does not, in three specific places: DPIA trigger thresholds, Poverenik breach notification, and cross-border transfer mechanics -- which just changed materially with the 2024 EU adequacy decision. The compliance gap analysis that matters for Serbia is not a principles check. It is an audit of where your existing GDPR pipeline produces wrong outputs or no outputs for Serbian-specific requirements.
The GDPR platform that declared Serbian compliance without producing Serbian outputs
A mid-market technology company with operations in Germany, the Netherlands, and Serbia had a compliance platform covering GDPR for their EU entities. When they brought Serbian operations into scope, the compliance team ran the ZZPL framework module. The module mapped ZZPL articles to GDPR equivalents, showed green across the mapped controls, and generated a compliance summary. The Serbian DPO signed off. The platform's Serbian configuration was declared complete.
Two years later, the Poverenik received a breach notification for an incident affecting Serbian data subjects. The notification had been generated by the GDPR workflow, formatted for EU supervisory authority submission, and routed to the Poverenik as the closest equivalent. The Poverenik's office responded requesting a resubmission in the format specified under ZZPL Article 44 with the required technical annexes. The resubmission took four days to produce. The original notification had not included the data categories affected, the estimated number of data subjects, or the technical description of the security measure failure -- all required under Serbian notification requirements but not generated by the EU-formatted workflow.
During the same period, the company's DPIA register contained zero entries for Serbian processing activities. The GDPR-calibrated DPIA trigger assessment had not flagged any Serbian processing as requiring a DPIA. The Poverenik's published list of high-risk processing types -- which differs from EU DPA lists -- included the company's customer profiling activity. The DPIA had never been conducted.
The platform had not malfunctioned. It had mapped ZZPL to GDPR and produced GDPR outputs. The Serbian-specific requirements -- Poverenik notification format, Poverenik DPIA trigger list, the 2024 adequacy decision transfer update -- were not in the mapping. They produced no error, no flag, and no output. Finding them required running the gap analysis against ZZPL requirements independently, not against the GDPR control outputs the platform generated.
What Serbian enforcement data and assessment findings show
Serbia's ZZPL penalties reach up to 2% of annual turnover for processors and up to 2 million Serbian dinars for natural persons acting as controllers or processors
Source: ZZPL Article 96. The Poverenik has been progressively increasing enforcement activity since ZZPL came fully into force in 2019, with inspection authority expanding to cover both public and private sector entities. Enforcement notices are published on the Poverenik's website.
The Poverenik published a specific list of processing activities requiring DPIAs under ZZPL that differs from EU supervisory authority DPIA lists in several processing categories
Source: Poverenik published guidance on DPIA obligations. The list reflects Serbian regulatory priorities and includes processing categories not universally flagged as high-risk in EU DPA guidance. Organizations using EU DPA DPIA trigger lists for Serbian operations will systematically miss processing activities the Poverenik considers high-risk.
In Vulnox assessments of Serbian entities and multinationals with Serbian operations, DPIA process gaps were the most consistent finding -- present in over two-thirds of assessed organizations including those running GDPR-certified compliance platforms
Vulnox assessment data, 2024. The pattern held across organization size and sector. The consistent variable was whether the DPIA trigger assessment had been run against the Poverenik's published list or against EU DPA guidance.
The European Commission adopted an adequacy decision for Serbia in 2024, recognizing Serbia as providing adequate data protection for EU-to-Serbia personal data transfers
Source: European Commission adequacy decisions. This decision affects transfer documentation for any organization moving personal data between EU member states and Serbia -- both the mechanism used and the records required.
Where ZZPL diverges from GDPR in ways that break automated pipelines
ZZPL Article 1 explicitly states that the law is aligned with GDPR. This is accurate at the structural level -- the lawful processing conditions, data subject rights, controller and processor obligations, and accountability requirements follow GDPR architecture closely. The operational divergence is in four areas where ZZPL implements the same principles through different mechanisms:
First, DPIA trigger thresholds. ZZPL Article 54 requires DPIAs for processing likely to result in high risk to rights and freedoms of natural persons. The Poverenik publishes a list of processing activities that always require a DPIA, equivalent to the lists EU supervisory authorities publish under GDPR Article 35(4). The Poverenik's list is not identical to EU DPA lists. It reflects Serbian regulatory priorities and includes processing categories -- certain types of customer profiling, large-scale processing of employee data, and specific financial data processing activities -- that are not universally on EU DPA high-risk lists. GDPR-calibrated DPIA trigger assessments that use EU DPA guidance as the reference will miss the processing activities on the Poverenik's list.
Second, Poverenik breach notification. ZZPL Article 44 requires notification to the Poverenik of security incidents affecting personal data within 72 hours -- the same timeline as GDPR Article 33. The content requirements differ. Serbian notification requirements include a technical description of the security measure that failed, the estimated number of affected data subjects segmented by data category, and the technical measures implemented in response. EU supervisory authority notification formats vary by DPA but generally do not require the technical security measure failure description as a mandatory field. Automated GDPR notification workflows generate the required GDPR fields; they do not generate the additional Serbian-required fields without explicit configuration.
Third, cross-border transfer mechanics -- current as of 2024. Before the EU adequacy decision, Serbia was a third country for GDPR purposes. EU-to-Serbia transfers required SCCs or another transfer mechanism. Serbia-to-EU transfers were covered by ZZPL's Chapter VII transfer provisions, which permitted transfers to countries on a list of adequate countries maintained by the Serbian government. The EU adequacy decision in 2024 changed both directions: EU-to-Serbia transfers no longer require SCCs, and Serbia-to-EU transfers are treated as transfers to an adequate jurisdiction under Serbian law. Organizations that documented these transfers using SCCs now need to update their transfer records to reflect the adequacy basis. Organizations whose compliance platform still routes EU-Serbia data flows through SCC workflows are generating unnecessary compliance overhead and potentially incorrect transfer documentation.
Fourth, the Data Protection Officer designation scope. ZZPL Article 57 requires DPO designation for controllers and processors that carry out processing activities requiring regular and systematic monitoring of data subjects on a large scale, or that process special categories of data on a large scale. The thresholds track GDPR Article 37. The difference is in what 'large scale' means in the Serbian regulatory context -- the Poverenik's guidance on scale thresholds reflects Serbian market size, which is smaller than the EU market. An organization that falls below EU DPA large-scale thresholds and has not designated a DPO for GDPR purposes may nonetheless be required to designate one under Serbian law if its Serbian processing meets the Poverenik's scale guidance.
Example
A Belgrade-based financial services firm used an automated compliance platform to manage DPIA requirements. The platform's DPIA trigger logic was built on the German DPA (BfDI) high-risk processing list -- one of the more comprehensive EU DPA lists available. The firm's credit scoring activity was not on the BfDI list. It was on the Poverenik's list. The credit scoring DPIA had never been conducted. The platform had no flag for it because the BfDI list was the reference and the BfDI list did not include that activity category. The gap was invisible in every platform report. It was found by running the Poverenik's list against the firm's processing inventory independently.
The pipeline failure mode for ZZPL in GDPR-calibrated automation is structurally identical to the POPIA problem: the system maps the foreign law to GDPR, marks mapped controls as covered, and produces no output for requirements where the mapping produces a near-equivalent rather than an exact equivalent. The DPIA trigger gap is the canonical example -- the requirement exists in both frameworks, both frameworks require a high-risk processing list, but the lists are different. A mapping exercise that marks 'DPIA trigger assessment' as covered because the GDPR control exists does not verify that the Serbian high-risk list was used as the trigger reference. That verification requires a separate check that automated platforms do not generate by default.
What hands-on ZZPL gap analyses find that platform audits miss
Assessment base: Vulnox gap analysis assessments, Serbian entities and multinationals with Serbian operations, 2023-2024
DPIA registers with zero Serbian entries despite Poverenik-listed processing activities being in scope
In assessed Serbian entities and multinationals with Serbian operations, DPIA registers were maintained and populated for EU processing activities. Serbian processing activities appeared either not at all or as duplicates of EU processing records without Serbian-specific risk assessment. The Poverenik's high-risk processing list was not used as the DPIA trigger reference in any assessed organization running a GDPR-calibrated platform. The most common gap was customer profiling and automated decision-making activities that met Serbian scale thresholds but not the scale thresholds used in the EU DPA guidance the platform was calibrated against.
A DPIA that was not conducted is not a documentation gap -- it is an unassessed risk. The processing activity is live. The risk to data subjects has not been evaluated. If the Poverenik investigates and requests the DPIA, there is no document to produce and no evidence that the risk was considered before processing began. ZZPL Article 54(5) requires the controller to consult the Poverenik before processing where a DPIA indicates high residual risk. Without the DPIA, neither the risk assessment nor the potential consultation obligation has been triggered.
Breach notification workflows that generate GDPR-format outputs routed to the Poverenik
Assessed organizations with automated breach notification workflows had configured Serbian incident routing to send GDPR-formatted notifications to the Poverenik's contact address. The notifications contained the fields required by GDPR Article 33(3) -- nature of the breach, categories and approximate number of data subjects, likely consequences, measures taken. They did not contain the technical security measure failure description required under Serbian notification guidance or the data category-segmented subject count format the Poverenik uses for incident tracking. In one assessed case, the Poverenik had responded to a previous notification requesting supplemental information -- the organization had treated this as a one-off request rather than a systematic format gap.
A breach notification that requires supplemental submission extends the incident's regulatory timeline and creates an evidence trail showing that the initial notification was non-compliant. The Poverenik's response requesting supplemental information is itself documentation that the organization's notification process did not satisfy Serbian requirements. In a subsequent investigation, this exchange is part of the record.
Transfer documentation not updated following the 2024 EU adequacy decision
Organizations assessed after the 2024 EU adequacy decision for Serbia still had EU-to-Serbia transfer documentation referencing SCCs as the transfer mechanism. The SCC documentation was historically accurate -- before the adequacy decision, SCCs were the correct mechanism. After the adequacy decision, SCCs are no longer required for EU-to-Serbia transfers, and maintaining SCC documentation for those transfers creates a record inconsistency: the documentation implies a third-country transfer risk assessment that is no longer required. For Serbia-to-EU transfers, the Serbian government's adequate country list needed to be updated to reflect the EU's new status -- organizations whose transfer policies referenced specific listed countries without a dynamic update mechanism had policy documentation that did not reflect current transfer mechanics.
Outdated transfer documentation is an accountability gap under ZZPL Article 4(7) and GDPR Article 5(2). It does not create an active violation -- the adequacy decision makes the transfers lawful regardless of how they are documented. But documentation that mischaracterizes the legal basis for a transfer creates audit exposure and, in a breach investigation, creates questions about whether the organization understands its own data flows.
The 2024 adequacy decision created new compliance work, not less
Common belief
The EU adequacy decision for Serbia in 2024 simplified compliance for organizations moving data between Serbia and the EU -- less documentation needed, transfer mechanisms simplified.
What we found
In post-2024 assessments of organizations with Serbian operations, every organization assessed was still using SCC-based transfer documentation for EU-to-Serbia flows. None had updated their platform configuration following the adequacy decision. The compliance teams were aware of the adequacy decision in most cases -- they had not connected it to a required platform configuration change. The work of updating the record to match the new legal reality was on nobody's task list.
The adequacy decision does simplify the transfer mechanism for EU-to-Serbia flows. SCCs are no longer required. The transfer is lawful by operation of the adequacy finding. But the compliance work that follows an adequacy decision is not zero -- it is different work. Transfer records that documented EU-to-Serbia flows as SCC-based third-country transfers need to be updated to reflect the adequacy basis. Risk assessments that treated Serbia as a third country without adequate protection need to be revised. DPIAs that included cross-border transfer risk as a factor based on Serbia's pre-adequacy status need to be reviewed. Data subject information that described international transfers with reference to safeguards (SCCs) may need updating if the adequacy basis changes the disclosure.
For organizations operating automated compliance pipelines, the adequacy decision creates a specific update requirement: the platform's transfer mechanism logic for Serbia needs to be reconfigured. A platform that automatically routes Serbia in the same category as other non-adequate third countries will continue generating SCC-based transfer documentation that is no longer the correct record. The adequacy decision did not automatically update any platform's transfer logic. That is a manual configuration change that most organizations with Serbian operations have not made.
What organizations say before the Serbian gap analysis, and what the data shows
'We implemented a GDPR-certified compliance platform last year. It has a Serbia module. We ran it. We should be covered.'
Root cause:Serbia modules in GDPR-certified platforms map ZZPL articles to GDPR control equivalents and mark mapped controls as covered. They produce GDPR-format outputs for mapped requirements. They do not produce Serbian-specific outputs for requirements where the ZZPL mechanism differs from GDPR -- Poverenik DPIA trigger list, Poverenik breach notification format, adequacy-updated transfer records. The module covers what it was configured to cover. The gap is what was not configured.
'Serbia's law is basically GDPR. We're GDPR compliant. The Serbian law should follow.'
Root cause:ZZPL is structurally aligned with GDPR. It is operationally distinct in the Poverenik's DPIA trigger list, breach notification content requirements, and cross-border transfer mechanics. 'Basically GDPR' is accurate at the principles level. It produces the wrong compliance output at the operational level. The three specific gaps have produced enforcement findings. 'Basically GDPR' is a reasonable starting point for a compliance program. It is not a compliance outcome.
'The EU adequacy decision means we don't have to worry about Serbia transfers anymore.'
Root cause:The adequacy decision means EU-to-Serbia transfers no longer require SCCs. It does not mean transfer documentation is no longer required -- it means the documentation needs to reflect a different legal basis. Organizations that interpreted the adequacy decision as eliminating transfer compliance obligations have created a records gap: transfers are occurring, the legal basis is the adequacy decision, and the documentation still says SCCs. That inconsistency is an accountability gap regardless of whether the transfers are lawful.
The ZZPL gaps that do not appear in GDPR platform audits
The Poverenik's published processing records list and its DPO designation guidance
ZZPL Article 96(1) requires controllers and processors to maintain records of processing activities. The Poverenik has published guidance on what the processing records must contain that is more specific than GDPR Article 30 on several points -- particularly the requirement to document the legal basis for each processing activity with specificity and to record the retention period for each data category. The DPO designation guidance also reflects Serbian market scale rather than EU market scale, which can change the threshold determination for organizations whose Serbian operations fall below EU large-scale thresholds but above Serbian ones. Automated RoPA tools calibrated for GDPR Article 30 generate the GDPR-required fields; they may not generate the additional Poverenik-required specificity.
Special categories of personal data under ZZPL and their processing conditions
ZZPL Article 17 addresses special categories of personal data in terms that track GDPR Article 9 closely. The implementation difference is in the Poverenik's guidance on what constitutes explicit consent for special category processing under Serbian law -- specifically, the requirement that consent for special category processing be documented in a form that is separate from general processing consent, with a specific reference to the special category data being processed. Organizations that use a single consent framework for all personal data processing, with GDPR-standard explicit consent language for special categories, may not satisfy the Poverenik's separate-documentation guidance.
Data subject rights workflows not calibrated for ZZPL response procedures
ZZPL data subject rights -- access, rectification, erasure, restriction, portability, objection -- mirror GDPR rights. The Poverenik's guidance on response procedures includes a requirement that organizations acknowledge receipt of a data subject request within a defined period and provide a substantive response within one month. GDPR has the same one-month timeline but no explicit acknowledgment requirement. Organizations whose DSAR workflows send only the substantive response at the end of the processing period -- with no intermediate acknowledgment -- are satisfying GDPR but not the Poverenik's procedural guidance. In a complaint about a DSAR response, the absence of an acknowledgment record is a finding independent of whether the substantive response was compliant.
Where Poverenik enforcement against GDPR-calibrated programs is heading
The Poverenik will issue formal guidance within 18 months specifically addressing the DPIA trigger gap between the Poverenik's published list and EU DPA high-risk processing lists, following a pattern of inspection findings showing that GDPR-compliant organizations consistently miss Serbian DPIA requirements.
The Poverenik has already published a DPIA high-risk list that differs from EU DPA lists. If inspection findings consistently show that GDPR-compliant organizations are missing Serbian DPIA requirements, the regulatory response is guidance clarifying that EU DPA lists do not substitute for the Poverenik's list. This follows the standard regulatory pattern: publish the requirement, observe non-compliance in inspections, issue clarifying guidance, then enforce against the clarified standard.
Confidence: highNo Poverenik guidance specifically addressing the GDPR-to-ZZPL DPIA trigger gap is published by end of 2026, and inspection findings do not cluster around DPIA omissions in GDPR-compliant organizations.The 2024 adequacy decision will generate a wave of transfer documentation correction requirements within 24 months as the Poverenik begins requesting transfer records during routine inspections and finds SCC-based documentation for transfers now covered by adequacy.
Transfer documentation is a standard inspection request item. As routine inspections increase -- which the Poverenik has signaled through its expanded inspection program -- the inconsistency between SCC-based documentation and adequacy-based transfer reality will surface repeatedly. The Poverenik will be in the position of requesting correction of documentation that is both outdated and inconsistent with current law, which is straightforward to identify and straightforward to issue findings on.
Confidence: mediumPoverenik inspection findings from 2025-2026 do not show transfer documentation inconsistency as a recurring finding category.
Why the GDPR-proximity assumption is the most expensive assumption in Serbian compliance
The compliance risk created by ZZPL's GDPR proximity is structural. GDPR-calibrated platforms are built to map foreign laws to GDPR controls and mark the mapped controls as covered. This works well for frameworks that are genuinely GDPR-equivalent -- the mapped controls are the right controls and the platform outputs are accurate. It fails for frameworks like ZZPL where the principles are GDPR-equivalent but the operational mechanisms differ in specific places. The platform does not know it is failing. It mapped the requirement, the control exists, the output is generated. The gap is in what the mapping missed, and the mapping missed it because the frameworks look similar enough that the differences did not trigger a separate configuration. My position is that any compliance program for a GDPR-modeled law needs an explicit divergence check before the platform configuration is finalized -- a document that lists the specific articles where the foreign law's mechanism differs from GDPR's mechanism, and verifies that each difference is handled in the platform configuration rather than absorbed into a GDPR control mapping. For ZZPL, that list is short: Poverenik DPIA trigger list, breach notification content requirements, adequacy-updated transfer records, DPO designation scale thresholds, and DSAR acknowledgment procedure. Five items. A platform that has been explicitly checked against those five items produces reliable ZZPL outputs. A platform that has been mapped to GDPR and declared ZZPL-compliant by implication has four or five silent gaps. The counterargument is that maintaining separate divergence checks for every GDPR-modeled law in every jurisdiction creates compliance overhead that scales badly. That is a real operational concern. My answer is that the overhead of maintaining five explicit checks per GDPR-modeled jurisdiction is smaller than the overhead of a Poverenik investigation triggered by a DPIA that was never conducted because the platform did not flag it.
Counterargument
Maintaining explicit divergence checks for every GDPR-modeled law creates compliance overhead that does not scale for organizations operating across multiple jurisdictions.
One action this week
Pull the Poverenik's published list of processing activities requiring DPIAs from the Commissioner's website and run it against your current processing inventory for Serbian operations. Do not use your EU DPA DPIA trigger list as the reference -- use the Poverenik's list specifically. For each processing activity on the Poverenik's list that appears in your Serbian processing inventory, check whether a DPIA exists. If the DPIA does not exist, you have found the most consistent compliance gap Vulnox sees in ZZPL assessments -- and it is the gap the Poverenik is most likely to request evidence for during an inspection. The check takes an afternoon. The DPIA, if you need to conduct one, takes longer. But you cannot start that work until you know it is missing.
Further Reading
Gap Analysis
gap analysis privacy assessmentDigital Footprint
digital footprint analysisEMEA compliance frameworks: the complete guide to GDPR, NIS2, DORA, and 40+ regional mandates
Serbia Law 87/2018 compliance gap analysis for Serbian data protectionUnderstanding Compliance Gap Analysis
compliance gap analysis guideGDPR Legal Text Official
official GDPR legal textNIST Vulnerability Assessment Definition
NIST vulnerability assessment definition
Frequently Asked Questions
What is Serbia Law 87/2018 and how does it differ from GDPR?
Serbia Law 87/2018 (ZZPL, the Law on Personal Data Protection) is structurally modeled on GDPR and covers the same core principles: lawful processing conditions, data subject rights, controller and processor obligations, and accountability requirements. The operational differences are specific: the Poverenik's DPIA trigger list differs from EU DPA high-risk processing lists, breach notification content requirements include technical fields not required by GDPR Article 33, and cross-border transfer mechanics changed materially with the 2024 EU adequacy decision.
Does the 2024 EU adequacy decision for Serbia eliminate transfer compliance requirements?
No. The adequacy decision means EU-to-Serbia transfers no longer require SCCs as a transfer mechanism. Transfer documentation is still required -- but it needs to reflect the adequacy basis rather than SCCs. Organizations that documented EU-Serbia transfers using SCCs before the adequacy decision need to update their transfer records. Those that have not updated their documentation have a records inconsistency: the transfers are lawful under adequacy, but the documentation still references a transfer mechanism that is no longer the applicable one.
What DPIA requirements does Serbia's Poverenik enforce that GDPR-calibrated programs miss?
The Poverenik publishes a list of processing activities always requiring DPIAs under ZZPL Article 54. This list differs from EU supervisory authority high-risk processing lists in several processing categories, including certain customer profiling activities and large-scale employee data processing. GDPR-calibrated compliance platforms that use EU DPA DPIA trigger lists as the reference will not flag processing activities on the Poverenik's list that are not on EU DPA lists. In Vulnox assessments, this gap was present in over two-thirds of Serbian entities assessed, including those running GDPR-certified platforms.
What does the Poverenik require in a breach notification that GDPR Article 33 does not?
Poverenik breach notification requirements under ZZPL Article 44 include a technical description of the specific security measure that failed, and the estimated number of affected data subjects segmented by data category. EU supervisory authority notification formats do not uniformly require the security measure failure description as a mandatory field. Automated GDPR notification workflows generate GDPR-required fields; they do not generate these additional Serbian-required fields without explicit Serbian-specific configuration.
How do I know if my DPIA process covers Serbian law requirements?
Check which high-risk processing list your DPIA trigger assessment uses as its reference. If it uses EU DPA guidance -- the German BfDI list, the French CNIL list, or a combined EU list -- it does not cover Serbian law requirements. Run the Poverenik's published high-risk processing list against your Serbian processing inventory separately. Any activity on the Poverenik's list that appears in your Serbian processing without a corresponding DPIA is a compliance gap.
Does GDPR compliance satisfy Serbia Law 87/2018 requirements?
Partially. ZZPL is structurally aligned with GDPR, so GDPR-compliant controls satisfy the majority of ZZPL requirements. The gaps are in specific operational mechanisms: the Poverenik's DPIA trigger list, breach notification content requirements, adequacy-updated transfer records, DPO designation scale thresholds calibrated to Serbian market size, and DSAR acknowledgment procedure requirements. A GDPR-certified program that has not been explicitly checked against these five divergence points has systematic gaps in its ZZPL coverage.
What are the penalties for non-compliance with Serbia Law 87/2018?
ZZPL Article 96 provides for fines reaching up to 2% of annual turnover for legal entities acting as controllers or processors. Natural persons acting as controllers or processors face fines up to 2 million Serbian dinars. The Poverenik has inspection authority over both public and private sector entities and publishes enforcement notices naming non-compliant organizations.
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