Responsibilities of a Vaccination Center in Cases of Personal Data Disclosure

The Vaccination Center is a medical facility responsible for storing and processing patients’ sensitive personal information. Any incident involving the disclosure of personal data at the Vaccination Center not only constitutes a violation of the law but also causes serious consequences. So, what is the responsibility of the Vaccination Center when a data subject’s personal data is disclosed under the latest regulations?

In this article, VDPC will analyze the specific legal obligations related to sensitive data that Vaccination Centers must comply with, while also clarifying the applicable administrative penalties in accordance with the regulations.

Legal basis:

• Article 3, 7, 8, 37 Law on Personal Data Protection 2025
• Article 46 Decree No. 98/2020/ND-CP as amended and supplemented by Decree 24/2025/ND-CP
• Article 4, 38 Decree 117/2020/ND-CP

1. Role of the Vaccination Center

The Vaccination Center may assume one of the following roles:

• Personal Data Controlling party(an agency, organization, or individual that determines the purposes and means of processing personal data.)
• Personal Data Processing party(an agency, organization, or individual that processes personal data on behalf of the Personal Data Controller or Controller and Processor under a contract)
• Personal Data Controlling and Processing party(an agency, organization, or individual that determines the purposes and means of processing personal data and directly processes the data)

Accordingly, depending on its role, the Vaccination Center will have corresponding responsibilities.

2. Responsibilities of the Vaccination Center as a Personal Data Controlling party

The responsibilities of a Personal Data Controller are as follows:

• Specify the responsibilities, rights, and obligations of the concerned parties to be complied with in agreements or contracts regarding personal data processing, pursuant to regulations
• Decide on the purposes and means of personal data processing in documents and agreements with personal data subject matters, ensuring compliance with the principles and contents 
• Adopt appropriate managerial and technical measures to protect personal data according to the law and review and update such measures if necessary
• Issue notices of violations against personal data protection regulations 
• Select an appropriate personal data processing party to process personal data
• Ensure the rights of personal data subject matters
• Assume responsibility before personal data subject matters for any damage arising from personal data processing
• Prevent unauthorized collection of personal data from its system, equipment, and service
• Cooperate with the Ministry of Public Security of Vietnam and competent state authorities in protecting personal data, providing information serving the investigation, and handling violations against personal data protection laws
• Implement other responsibilities pursuant to regulations.

3. Responsibilities of the Vaccination Center as a Personal Data Processing party

The responsibilities of a Personal Data Processor are as follows:

• Only receive personal data after concluding an agreement or contract on personal data processing with the personal data controlling party or personal data processing and controlling party
• Process personal data in compliance with the agreement or contract concluded with the personal data controlling party 
• Implement all measures to protect personal data
• Assume responsibility before Personal data controlling party, Personal data processing and controlling party  for any damage arising from personal data processing
• Prevent unauthorized collection of personal data from its system, equipment, and service
• Cooperate with the Ministry of Public Security of Vietnam and competent state authorities in protecting personal data, providing information serving the investigation, and handling violations against personal data protection laws
• Implement other responsibilities pursuant to regulations.

4. Responsibilities of the Vaccination Center as a Personal Data Controlling and Processing party

The responsibilities of a Personal Data Controlling and Processing are as follows:

• Specify the responsibilities, rights, and obligations to be complied with of concerned parties in agreements or contracts concerning personal data processing
• Only receive personal data after concluding an agreement or contract on personal data processing with the personal data controlling party or personal data processing and controlling party
• Decide on the purposes and means of personal data processing in documents and agreements with personal data subject matters, ensuring compliance with the principles and contents
• Adopt appropriate managerial and technical measures to protect personal data and review and update such measures if necessary
• Process personal data in compliance with the agreement or contract concluded with the personal data controlling party 
• Issue notices of violations against personal data protection regulations

In addition, there are other responsibilities such as:

• Select an appropriate personal data processing party to process personal data
• Ensure the rights of personal data subject matters
• Implementing all personal data protection measures as required by law
• Assume responsibility before personal data subject matters for any damage arising from personal data processing
• Assume responsibility before Personal data controlling party, Personal data processing and controlling party  for any damage arising from personal data processing
• Prevent unauthorized collection of personal data from its system, equipment, and service
• Cooperate with the Ministry of Public Security of Vietnam and competent state authorities in protecting personal data, providing information serving the investigation, and handling violations against personal data protection laws
• Implement other responsibilities pursuant to regulations.

5. What responsibilities does a Vaccination Center bear when the personal information or data of a data subject is disclosed?

Regarding responsibilities, in the event of a personal data breach of a data subject, a Vaccination Center may be held liable as follows:

1. Pursuant to the Law on Personal Data Protection, the disclosure of personal data constitutes a prohibited act. Accordingly, organizations or individuals committing such violations may be subject to administrative sanctions, with a maximum fine of up to 3 billion VND. With respect to civil liability, violators may also be required to compensate data subjects for any damages incurred, where applicable.
2. According to Decree No. 98/2020/NĐ-CP, the act of transferring consumers’ information to a third party without the consumers’ consent may be subject to administrative fines ranging from 30,000,000 VND to 40,000,000 VND.
3. Pursuant to Decree No. 117/2020/NĐ-CP, the act of disclosing a patient’s medical condition, information provided by the patient, or medical records held by a Vaccination Center may result in administrative fines ranging from 2,000,000 VND to 6,000,000 VND.
4. In addition, incidents of personal data disclosure may adversely affect the honor, reputation, revenue, or even the operational activities of a Vaccination Center, particularly where the incident occurs on a serious scale.

CONCLUSION

Vaccination Centers bear a very high legal responsibility in safeguarding sensitive personal data. Ensuring the security of medical information is a critical factor, requiring the center to regularly review its security systems and train personnel in accordance with strict standards prescribed by law.

The above outlines the Responsibilities of a Vaccination Center in Cases of Personal Data Disclosure. Should you have any further questions regarding this matter, please contact VDPC for the most accurate advice and support.

Sincerely !

Zalo: 098.159.5243

The above is a summary and analysis of legal regulations based on the Advisor’s perspective for reference purposes only. This content does not apply to any specific real-world case, and VDPC shall not be held liable for any application by readers based on the aforementioned information without obtaining professional consultation from experts. Readers are kindly requested to contact us for precise advice tailored to your specific case of interest. Sincerely!

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