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Compliance

Data Protection and Digitization: Complying with Law 18.331

How to comply with Law 18.331 and 25.326 while scaling your digitization. 24-hour deletion protocol and encryption of sensitive data in mass processing.

March 20, 2025

Mass digitization and data protection: a tension that can be resolved

Scaling document digitization means processing sensitive data at high volume: customer personal data, medical information, financial records. In Uruguay and Argentina, this triggers concrete legal obligations under Law 18.331 (LPDP) and Law 25.326.

Many companies postpone digitization out of fear of regulatory risk. But the reality is that keeping sensitive data on paper is riskier than processing it digitally with the right controls in place.


Applicable regulatory framework

Law 18.331 — Uruguay (LPDP)

  • Article 5: Informed consent for personal data processing.
  • Article 10: Security principle — adopt technical and organizational measures.
  • Article 12: Right of access — data subjects must be able to access their data in an intelligible format.
  • Article 34: Outsourcing — the data controller maintains obligations even when delegating processing.

Law 25.326 — Argentina

  • Article 9: Data security — adoption of technical measures to guarantee integrity.
  • Article 11: Transfer — data transfer to third-party processors under contract.
  • Article 25: Provision of computerized personal data services with written contract.

Our compliance protocol

1. Automatic deletion in 24 hours

Once structured data is delivered and receipt is confirmed, original documents and any intermediate data are deleted from our infrastructure. No exceptions.

Why 24 hours? Because it minimizes the exposure window. We don’t retain data “just in case.” If you need reprocessing, send the documents again.

2. End-to-end encryption

StageProtocol
Document transferTLS 1.3
Temporary storageAES-256 at rest
Structured data deliveryTLS 1.3 + digital signature

3. Processing isolation

Each client has an isolated processing environment. One client’s documents never share computational resources or storage with another’s.

4. Full audit trail

We generate immutable logs for every operation:

  • Ingestion date and time for each document.
  • Extraction model applied.
  • Validation result.
  • Delivery date and time.
  • Confirmed deletion date and time.

These logs are available on demand for your internal or regulatory audit processes.


The risk of not digitizing

While evaluating the risk of processing data digitally, consider the risk of not doing so:

  • Physical documents without access control: Anyone with archive access can view sensitive data without leaving a trace.
  • No traceability: No log of who accessed which document or when.
  • Deterioration: Paper documents degrade, get lost, and are destroyed by accidents.
  • Non-compliance with right of access: If a data subject requests their data under Law 18.331, searching through a physical archive of millions of documents is unfeasible within legal deadlines.

How to get started

  1. Send a document sample with sensitive data (use test or anonymized data if preferred).
  2. Receive structured data in 24h along with an accuracy report.
  3. Verify deletion: Request confirmation that documents were removed from our infrastructure.

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