Agreement Between the President of the PL SA the Church Data Protection Inspector

Agreement Between the President of the Personal Data Protection Office and the Church Data Protection Inspector of the Polish Autocephalous Orthodox Church

On 15 October 2025, Mirosław Wróblewski, President of the Personal Data Protection Office, and Fr Andrzej Lewczak, Church Data Protection Inspector of the Polish Autocephalous Orthodox Church (PAKP), signed an agreement on cooperation and mutual exchange of information. This document holds particular significance due to the fact that PAKP is the second largest Church in Poland – officially comprising over half a million faithful.

The agreement sets out the principles, scope and form of cooperation between the President of the Personal Data Protection Office and the Church Data Protection Inspector, particularly in the area of educational, training and informational activities aimed at ensuring the protection of individuals’ rights in connection with the processing of personal data. These activities will be carried out with respect for the independence and competences of both parties.

The agreement was signed in accordance with the principle of autonomy and independence of churches and other religious associations, as provided for in the Constitution of the Republic of Poland, which applies to PAKP, as well as other normative acts governing the relationship between the Polish state and this Church. The document is also based on PAKP’s declarations regarding the application of personal data protection principles in line with Regulation 2016/679 (GDPR), and implements the possibility (provided for in the 2018 Personal Data Protection Act) of concluding a cooperation agreement between the President of the Personal Data Protection Office and an independent supervisory authority established under Article 91(2) of the GDPR, relating to the supervision of churches and religious associations that apply specific data protection rules, provided these are aligned with the GDPR.

The signed document refers to the need to reconcile data protection with the exercise of the fundamental right to religious freedom, guaranteed under international, European and Polish law.

This signed agreement is the second of its kind, following the 2019 agreement signed by the President of the Personal Data Protection Office with the Church Data Protection Inspector representing the Catholic Church.

The agreement is the result of cooperation between the President of UODO and supervisory authorities. In May 2025, an expert seminar was held by the President of UODO with representatives of churches and religious associations in Poland entitled “Current Challenges in Personal Data Protection in Religious Associations in Poland”.

The Polish Autocephalous Orthodox Church has existed since 1924, when it obtained autocephaly (independence) from the Patriarchate of Constantinople. Its roots on Polish territory date back to the 9th century AD. It comprises over half a million faithful who gather in more than three hundred churches across seven dioceses. It is the second largest Church in Poland. PAKP is part of the Universal Orthodox Church, maintaining unity with it in matters of dogma and canon law. It is independent of any foreign spiritual or secular authority. Its jurisdiction covers all Orthodox parishes within Poland.