Project timeline: June 2021 – January 2024, launch in early 2026
Contracting entity: e-Governance Academy, Ministry of Digital Transformation of Ukraine, State Center of Information Resources of Ukraine
Partners: Soft Xpansion Ukraine, Institute of Computers Technologies LLC
Ukraine has contracted Cybernetica to implement the Personal Data Access Monitoring Solution (PDAMS), a privacy-enhancing system designed to allow citizens to track who accesses their personal data and why.
This project represents a significant step toward GDPR compliance and demonstrates how digital infrastructure can strengthen citizen privacy and build trust in government.
Project Background
Ukraine has long prioritised building trustworthy digital infrastructure and embedding privacy by design, basing its digitalisation choices on these principles from the outset. This commitment has driven the country's rapid digital transformation, bringing significant benefits to citizens and government alike.
As more services moved online and data sharing between institutions increased, Ukraine sought to build on this foundation and:
- further strengthen public trust
- proactively address concerns over data privacy
- encourage greater service uptake.
By 2021, Ukraine had already established critical digital infrastructure through Trembita, its e-Government Interoperability System. Implemented by Cybernetica using UXP technology and adopted by hundreds of organisations, Trembita enables seamless data exchange across government entities, embodying the principle of "making data run, not people."
While this platform successfully eliminated institutional silos and accelerated digital service delivery, it created a new imperative: citizens needed visibility into how their personal data was being accessed and used across this interconnected system.
To address this need, Cybernetica was contracted to develop the Personal Data Access Monitoring Solution (PDAMS), built on UXP's Access Tracking capabilities. The development drew on lessons from Estonia's Data Tracker system while requiring new development to meet Ukraine's scale and specific requirements. These included:
- seamless integration with the existing Trembita platform
- compliance with strict regulatory and software certification standards
- efficient deployment processes for diverse participating organisations.
The system is now fully developed, with official launch scheduled for early 2026.
Personal Data Access Monitoring Solution (PDAMS)
The PDAMS solution is designed to protect the digital rights of Ukrainian citizens and foster trust in institutions by ensuring adherence to data protection and privacy regulations.
For citizens, PDAMS will deliver visibility into personal data usage. Through the Diia app, citizens receive real-time notifications and can see exactly who accessed their data and the stated purpose, which organisation published it originally, and which entities collected the data.
When data is accessed through Trembita, PDAMS automatically records comprehensive metadata: timestamp, purpose, specific data fields requested, and requesting entity. This level of overview would be virtually impossible in paper-based systems, making any misuse traceable and addressable.
For organisations, PDAMS will serve as a compliance tool, providing automated verification that data access aligns with legal requirements and creating standardised audit trails across all entities using Trembita. This reduces the burden on individual organisations to develop their own compliance tracking systems, creating a unified, government-wide approach that ensures accountability while reducing administrative overhead.
Cybernetica’s contribution
Cybernetica's role in the PDAMS project encompassed three primary areas:
- technical development
- ongoing support and maintenance
- security certification.
The development phase included software development, installation and configuration, as well as integration with the existing Trembita interoperability platform and comprehensive quality assurance.
Beyond technical development, Cybernetica provided user training, technical consultation, and additional support to ensure smooth implementation of the PDAMS.
Impact of the project
The impact of the PDAMS solution is threefold.
For citizens, PDAMS will return control over personal data use, enabling enhanced privacy and data protection. Rather than relying on trust alone, individuals will have clear information about who accesses their personal data and for what purpose. This transparency mechanism is expected to increase trust in Ukrainian digital society as a whole, helping to improve the uptake of digital services that some citizens might otherwise be hesitant to use.
For institutions, PDAMS streamlines compliance with regulatory and operational requirements. As every request for personal data is registered, organisations benefit from automated documentation of data access without needing to develop their own tracking systems.
At a national level, PDAMS brings Ukraine closer to European data protection standards. The Access Tracking system is designed to meet the requirements of the GDPR, demonstrating Ukraine's commitment to privacy rights while advancing its European integration objectives. The system enhances control and accountability surrounding data, making misuse easier to detect and deter.
Looking forward
As Ukraine continues its digital journey, PDAMS represents a model for other countries seeking to balance innovation with privacy protection. The system demonstrates that transparency and efficiency can coexist in digital government, and that citizens don’t have to sacrifice privacy for the convenience of online services.
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For more information about the PDAMS Access Tracking solution, please contact us or continue reading: